United States securities and exchange commission logo March 23, 2023 Herman Billung Chief Executive Officer Himalaya Shipping Ltd. S.E. Pearman Building, 2nd floor 9 Par-la-Ville Road Hamilton HM 11, Bermuda Re: Himalaya Shipping Ltd. Amendment No. 1 of Registration Statement on Form F-1 Filed March 20, 2023 File No. 333-270337 Dear Herman Billung: 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 comments in our March 16, 2023 letter. Amendment No. 1 of Registration Statement on Form F-1 Key Performance Indicators Earnings Premium, page 64 1. We note your disclosure that you estimate a Himalaya-built vessel could earn up to 70% more than a comparable conventional Capesize vessel. Please revise your disclosure to provide your basis for such estimate, including all material assumptions. Herman Billung FirstName LastNameHerman Billung Himalaya Shipping Ltd. Comapany March NameHimalaya Shipping Ltd. 23, 2023 March2 23, 2023 Page 2 Page FirstName LastName You may contact Lily Dang, Staff Accountant at 202-551-3867 or Mark Wojciechowski, Staff Accountant at 202-551-3759 if you have questions regarding comments on the financial statements and related matters. Please contact Michael Purcell, Staff Attorney at 202-551-5351 or Laura Nicholson, Special Counsel at 202-551-3584 with any other questions. Sincerely, Division of Corporation Finance Office of Energy & Transportation cc: James McDonald