Mail Stop 3561

                                                                 September 24,
2018


    Adeline Gu
    Chief Financial Officer
    China Recycling Energy Corporation
    4/F, Tower C
    Rong Cheng Yun Gu Building
    Keji 3rd Road, Yanta District
    Xi'an City, Shaanxi Province
    China 710075

            Re:    China Recycling Energy Corporation
                   Form 10-K for the Fiscal Year Ended December 31, 2017
                   Filed April 13, 2018
                   Response Dated September 20, 2018
                   File No. 1-34625

    Dear Ms. Gu:

           We have reviewed your September 20, 2018 response to our comment
letter 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 these comments within ten business days by
providing the requested
    information or advise us as soon as possible when you will respond. If you
do not believe our
    comments apply to your facts and circumstances, please tell us why in your
response.

           After reviewing your response to these comments, we may have
additional comments.
    Unless we note otherwise, our references to prior comments are to comments
in our September
    7, 2018 letter.

    Item 8. Financial Statements and Supplementary Data

    1. Organization and Description of Business

    Erdos TCH   Joint Venture, page F-6

        1. We reviewed your response to comment 1. Please explain to us in
detail how you
           concluded the modification did not change the classification of the
lease referencing
           authoritative literature that supports your conclusion. Please also
clarify for us whether
 Adeline Gu
China Recycling Energy Corporation
September 24, 2018
Page 2

       you considered payments based on actual electricity sold as minimum
lease payments
       when evaluating the modified terms referencing authoritative literature
that supports your
       conclusion. If so, tell us what minimum payments you assumed and how you
estimated
       such amounts. In addition, please explain your accounting conclusions
and show us how
       your financial statements would change had you not considered payments
based on actual
       electricity sold as minimum lease payments. Finally, please explain why
you believe
       ASC 450-20-25-2 should be considered when evaluating this transaction.

      You may contact Adam Phippen, Staff Accountant, at (202) 551-3336 or me
at (202)
551-3344 with any questions.


                                                           Sincerely,

                                                           /s/ William H.
Thompson

                                                           William H. Thompson
                                                           Accounting Branch
Chief
                                                           Office of Consumer
Products