CHINA BIOPHARMACEUTICALS HOLDINGS

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

                                                                    June 2, 2006
Ms. Song P. Brandon
Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549

         Re:      China Biopharmaceuticals Holdings, Inc. (the "Company")
                  Registration Statement on Form SB-2 File No. 333-132693
                  -------------------------------------------------------

Dear Ms. Brandon:

         In response to the letter from the Securities  and Exchange  Commission
(the  "Commission"),  dated June 2, 2006,  and pursuant to Rule 477  promulgated
under the  Securities Act of 1933, as amended,  the Company hereby  respectfully
requests that its Post-Effective  Amendment No. 1 to the Registration  Statement
on Form SB-2, Commission File No. 333-132693 (the "Post-Effective  Amendment No.
1"), be immediately  withdrawn and that an order of the Commission granting such
withdrawal be granted.

         Upon the withdrawal of the  Post-Effecive  Amendment No. 1, the Company
shall  register  the  additional  shares  of  common  stock  covered  under  the
Post-Effective  Amendment  No.  1 on a new  short-form  registration  statement.

         If you have any  questions  regarding  the  foregoing  application  for
withdrawal,  please  free to  contact  Howard  Jiang  (212-891-3982)  of Baker &
McKenzie,  1114 Avenue of the Amercias,  New York, New York 10036, the Company's
outside counsel.


                                         Very truly yours,

                                         China Biopharmaceuticals Holdings, Inc.

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