United States securities and exchange commission logo





                              July 18, 2022

       Zhanchang Xin
       CEO
       Qilian International Holding Group Ltd
       Jiuquan Economic and Technological Development Zone
       Jiuquan City, Gansu Province, 735000
       People   s Republic of China

                                                        Re: Qilian
International Holding Group Ltd
                                                            CIK 0001779578
                                                            Form 20-F/A1 for
Fiscal Year Ended September 30, 2021
                                                            Filed June 30, 2022
File No. 001-39805

       Dear Mr. Xin:

               We have reviewed your June 30, 2022 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 April 28, 2022 letter.

       Amendment No. 1 to Form 20-F for Fiscal Year Ended September 30, 2021

       Introduction, page 5

   1.                                                   We note that your
definition of "China" or the "PRC" excludes Hong Kong and Macau. In
                                                        future filings, please
revise your disclosure to remove the exclusion of Hong Kong and
                                                        Macau from your
definition of "China" or the "PRC."
   2.                                                   We note your response
to prior comment 2 and reissue in part. In future filings, please
                                                        prominently disclose
here and at the outset of Item 3 whether your auditor is subject to the
                                                        determinations
announced by the PCAOB on December 16, 2021 and whether and how
                                                        the Holding Foreign
Companies Accountable Act and related regulations, including the
                                                        Accelerating Holding
Foreign Companies Accountable Act, if enacted, will affect your
                                                        company.
 Zhanchang Xin
Qilian International Holding Group Ltd
July 18, 2022
Page 2
Financial Information Related to the VIE, page 13

3.       Prior comment 9 requested separate line items for intercompany
amounts, including
         intercompany balances, activities and cash flows on a gross basis.
Please provide
         disclosure to clarify how you have presented service fees levied by
the WFOE pursuant to
         the Exclusive Service Agreement. Tell us the nature of the $4.8
million in amounts due to
         the VIE from the Parent and WFOE as of September 30, 2021, describe
the changes from
         the $6.4 million due from the WFOE as of September 30, 2020, and
explain how these
         intercompany amounts originated.
       You may contact Al Pavot at 202-551-3738 or Terence O'Brien at
202-551-3355 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Tyler Howes at 202-551-3370 or Jason Drory at 202-551-8342 with any
other questions.



FirstName LastNameZhanchang Xin                              Sincerely,
Comapany NameQilian International Holding Group Ltd
                                                             Division of
Corporation Finance
July 18, 2022 Page 2                                         Office of Life
Sciences
FirstName LastName