ZK International Group Co., Ltd.

No. 678 Dingxiang Road, Binhai Industrial Park

Economic & Technology Development Zone

Wenzhou, Zheijiang Province

People’s Republic of China 325025

June 12, 2017

Via E-Mail

Pamela A. Long

Assistant Director

Office of Manufacturing and Construction

U.S. Securities and Exchange Commission

Washington, D.C. 20549-4631

Registration Statement on Form F-1

Submitted May 24, 2017

File No. 333-218198

Dear Ms. Long:

We are in receipt of your comment letter dated June 1, 2017 regarding the above referenced filing. As requested in your letter, we have provided responses to the questions raised by the Staff. For your convenience, the matters are listed below, followed by our responses:

Prospectus’ Outside Front Cover Page; Underwriting, page 85

RESPONSE: We note the Staff’s comment, and in response thereto, respectfully advise the Staff that we have revise the disclosure on the cover page to clarify that all funds will be returned promptly to investors within five business days if we do not sell at least 1,000,000 ordinary shares by September 30, 2017. In addition, we respectfully include the executed escrow deposit agreement with Signature Bank as Exhibit 10.18 to the amended registration statement.

We are substantially dependent upon our senior management…, page 17; Management, page 63

RESPONSE: We note the Staff’s comment, and in response thereto, respectfully advise the Staff that we have revised the disclosure on page 17 to clarify that Mr. Jiancong Huang is currently our Chief Executive Officer and Chairman of the Board.

We plan to have a classified board structure..., page 27; Board of Directors, page 64; Director Compensation, page 67

RESPONSE: We note the Staff’s comment, and in response thereto, respectfully clarify for the Staff that we do not plan to have a classified board structure and therefore have removed the risk factor on page 27. We have further revised our disclosure on pg 67 to state that the current term of each director expires upon one year.

Board Committees, page 65

RESPONSE: We note the Staff’s comment, and in response thereto, respectfully advise the Staff that we provide the members of each board committee and respective chair on page 65 of the amended registration statement. We also provide such information below for the Staff’s review.

Compensation Committee, page 66; Governance Committee, page 66

RESPONSE: We note the Staff’s comment, and in response thereto, respectfully advise the Staff that it is Company’s understanding that the SEC has mandated new rules to ensure the accuracy of disclosing executive compensation pursuant to Item 402(c)(2)(x) of Regulation S-K. Smaller reporting companies, and foreign private issuers such as our company would not be subject to the requirement. We respectfully take the position that our Compensation Committee has an obligation to our shareholders to ensure that c-suite level compensation and employee stock option award programs, if any, accurately reflect the performance of our company. Conversely, the Governance Committee, while the responsibilities of which may appear joint in nature with that of the Compensation Committee, is to review any “red flags” or issues that may arise out of the Compensation Committee compensation and award recommendations and report them to the Board of Directors. The committees themselves, at times, may be collaborative but will not coordinate as the process is intended to be a “checks and balance” approach. It is being set up as an internal control mechanism that would safeguard against fraud and errors due to omission. (pg 66)

Underwriting, page 85

RESPONSE: We note the Staff’s comment, and in response thereto, respectfully clarify for the Staff that Signature Bank will act as the escrow agent for this offering. In addition, we respectfully include the executed escrow deposit agreement with Signature Bank as Exhibit 10.18 to the amended registration statement.

Financial Statements

General

RESPONSE: We note the Staff’s comment, and in response thereto, respectfully note the Staff’s comment. We also respectfully advise the Staff that our fiscal year end is September 30 and therefore our six-month unaudited interim financial statements would be as of March 31, 2017.

We hope this response has addressed all of the Staff's concerns relating to the Comment Letter. Should you have additional questions regarding the information contained herein, please contact our outside securities counsel William S. Rosenstadt, Esq. or Mengyi "Jason" Ye, Esq. of Ortoli Rosenstadt LLP at wsr@ortolirosenstadt.com or jye@ortolirosenstadt.com.