United States securities and exchange commission logo September 19, 2022 Teck Chia Chief Executive Officer CBL International Ltd Suite 19-9-6, Level 9, UOA Centre No. 19 Jalan Pinang 50450 Kuala Lumpur, Malaysia Re: CBL International Ltd Amendment No. 1 to Registration Statement on Form F-1 Filed September 7, 2022 File No. 333-267077 Dear Mr. Chia: We have reviewed your amended registration statement and have the following comment. In our comment, 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 comment applies 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 our comment, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our September 6, 2022 letter. Amendment No. 1 to Form S-1 filed September 7, 2022 Summary Consolidated Financial Data, page 14 1. Please revise your summary financial data to include the financial data as of and for the six months ended June 30, 2022 and 2021. Teck Chia FirstName LastNameTeck Chia CBL International Ltd Comapany 19, September NameCBL 2022 International Ltd September Page 2 19, 2022 Page 2 FirstName LastName You may contact Patrick Kuhn at 202-551-3308 or Lyn Shenk at 202-551-3380 if you have questions regarding comments on the financial statements and related matters. Please contact Scott Anderegg at 202-551-3342 or Mara Ransom at 202-551-3264 with any other questions. Sincerely, Division of Corporation Finance Office of Trade & Services