United States securities and exchange commission logo April 27, 2020 Gengchen Han Chairman of the Board and Chief Executive Officer Origin Agritech Limited No. 21 Sheng Ming Yuan Road Changping District, Beijing China 102206 011-86-10-5890-7566 Re: Origin Agritech Limited Registration Statement on Form F-1 Filed April 16, 2020 File No. 333-237712 Dear Dr. Han: We have limited our review of your registration statement to those issues we have addressed in our 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. Registration Statement on Form F-1 filed April 16, 2020 General 1. We note your Form 6-K filed March 10, 2020 indicating that you received notice from the NASDAQ Stock Market that you had a capital deficiency under the continued listing rules of NASDAQ and your press release dated April 15, 2020 indicating that you received RMB137.66 million from Beijing Changping Technology Innodevelop Group (BC-TID) and entered into a definitive framework agreement with BC-TID. Please revise your prospectus to disclose these events. Gengchen Han Origin Agritech Limited April 27, 2020 Page 2 We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate time for us to review any amendment prior to the requested effective date of the registration statement. Please contact Irene Paik at 202-551-6553 or Joseph McCann at 202-551-6262 with any questions. Sincerely, FirstName LastNameGengchen Han Division of Corporation Finance Comapany NameOrigin Agritech Limited Office of Life Sciences April 27, 2020 Page 2 cc: Andrew D. Hudders, Esq. FirstName LastName