China Biopharmaceutical Holdings, Inc.
Suite 1601, Building A
Jinshan Tower,  No. 8 Shan Xi Road
Nanjing, Jiangsu, China
Fax: 86-25-83205759


April 6, 2006
VIA EDGAR

Mr. Carlton Tartar
Assistant Chief Accountant
Division of Corporate Finance
Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549

RE:      China Biopharmaceutical Holdings, Inc. - Item 4.01 Form 8-K

In  response  to the letter of  comments,  dated  March 30,  2006 (the  "Comment
Letter"),  issued  by the  Staff  of  the  Commission,  China  Biopharmaceutical
Holdings,  Inc. (the "Company") has amended its current report on Form 8-K filed
on December 29, 2005. The Company further acknowledges that:

         o        the Company is  responsible  for the  adequacy and accuracy of
                  the disclosure in the filing;

         o        staff  comments or changes to  disclosure in response to staff
                  comments  do not  foreclose  the  Commission  from  taking any
                  action with respect to the filing; and

         o        the Company may not assert staff  comments as a defense in any
                  proceeding initiated by the Commission or any person under the
                  federal securities laws of the United States.


                                         Very truly yours,


                                         CHINA BIOPHARMACEUTICAL HOLDINGS, INC.

                                         By: /s/ Peng Mao
                                            ------------------------------------
                                            Name:   Peng Mao
                                            Title:  Chairman and Chief Executive
                                                    Officer