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                              December 8, 2020

       Zhanchang Xin
       Chief Executive Officer
       Qilian International Holding Group Ltd
       Jiuquan Economic and Technological Development Zone
       Jiuquan City, Gansu Province
       People   s Republic of China

                                                        Re: Qilian
International Holding Group Ltd
                                                            Amendment No. 6 to
Registration Statement on Form F-1
                                                            Filed November 23,
2020
                                                            File No. 333-234460

       Dear Mr. Xin:

             We have reviewed your amended registration statement 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 this letter by amending your registration
statement and providing the
       requested information. If you do not believe our comments apply to your
facts and
       circumstances or do not believe an amendment is appropriate, please tell
us why in your
       response.

              After reviewing any amendment to your registration statement and
the information you
       provide in response to these comments, we may have additional comments.
Unless we note
       otherwise, our references to prior comments are to the oral comments
issued on August 25, 2020.

       Amendment No. 6 to Registration Statement on Form F-1

       Use of Proceeds, page 32

   1.                                                   As we previously
requested, please revise the table on page 32 to reflect an offering size
                                                        of 5,000,000 Ordinary
Shares.
       Business
       Honors, Awards and Qualifications
       Awards, page 73

   2.                                                   We note your revised
disclosure on page 73 regarding your award of Specialized and
 Zhanchang Xin
Qilian International Holding Group Ltd
December 8, 2020
Page 2
         Innovative Little Giant Enterprise of China. Please briefly explain
the criteria for
         selection for this award so that investors understand the significance
of the award.
Executive Compensation, page 97

3.       Please update your executive and director compensation disclosure to
include any
         compensation for the fiscal year ended September 30, 2020 or explain
why you are unable
         to do so.
       You may contact Bonnie Baynes at 202-551-4924 or Sharon Blume at
202-551-3474 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Sonia Bednarowski at 202-551-3666 or Dietrich King at 202-551-8071 with
any other
questions.



FirstName LastNameZhanchang Xin                                Sincerely,
Comapany NameQilian International Holding Group Ltd
                                                               Division of
Corporation Finance
December 8, 2020 Page 2                                        Office of Life
Sciences
FirstName LastName