November 12, 2019

Roger May
Chief Executive Officer
Graphene & Solar Technologies Limited
433 N. Camden Dr., Ste. 600
Beverly Hills, CA 90210

       Re: Graphene & Solar Technologies Limited
           Form 10-K for the fiscal year ended September 30, 2018
           Filed January 23, 2019
           File No. 333-174194

Dear Mr. May:

       We have reviewed your October 31, 2019 response to our comment letter
and have the
following comments. In some of our comments, we may ask you to provide us with
information
so we may better understand your disclosure.

       Please respond to these comments within ten business days by providing
the requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comments apply to your facts and circumstances, please tell us why in your
response.

      After reviewing your response to these comments, we may have additional
comments. Unless we note otherwise, our references to prior comments are to
comments in our
September 18, 2019 letter.

Form 10-K for the fiscal year ended September 30, 2018 filed January 23, 2019

Item 2. Properties, page 4

1.     We note your response to comments 1 to 3. Please provide your proposed
draft disclosure
       and tell us if these changes will be incorporated in your 10-K for your
fiscal year ended
       September 30, 2019.
2.     We note your response to comment 4. Please note that only proven and
probable reserves
       based on a final feasibility study may be disclosed in filings with the
United States
       Securities and Exchange Commission pursuant to the Instructions to
Paragraph (b)(5) of
       Industry Guide 7. It appears the 15 million tons of high purity quartz
that are disclosed in
       your filing are only defined to the inferred resource category. Inferred
resources cannot
       be moved to a proven or probable reserve category without additional
geological work.
       Please revise to remove this tonnage and grade estimate from your
filing.
 Roger May
Graphene & Solar Technologies Limited
November 12, 2019
Page 2
3.    Additionally as a company with no mineral reserves you must be classified
as an
      exploration stage company pursuant to Paragraph (a)(4)(i) of Industry
Guide 7. Please
      revise your filing to clarify that you are an exploration stage company
until you have
      mineral reserves.
       You may contact John Coleman at 202-551-3610 or Pam Howell at
202-551-3357 if you
have questions regarding comments.



                                                          Sincerely,
FirstName LastNameRoger May
                                                   Division of Corporation
Finance
Comapany NameGraphene & Solar Technologies Limited
                                                   Office of Energy &
Transportation
November 12, 2019 Page 2
cc:       David Fickson
FirstName LastName