United States securities and exchange commission logo
September 17, 2021
Qimin Zhou
Chief Financial Officer
China Eastern Airlines Corporation Limited
5/F, Block A2, Northern District, CEA Building
36 Hongxiang 3rd Road, Minhang District, Shanghai
The People s Republic of China
Re: China Eastern
Airlines Corporation Limited
Form 20-F for the
Fiscal Year Ended December 31, 2020
Filed April 28,
2021
File No. 001-14550
Dear Mr. Zhou :
We have reviewed your filing 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.
1. To the extent material,
discuss the indirect consequences of climate-related regulation or
business trends, such
as the following:
decreased demand
for services that produce significant greenhouse gas emissions or
are related to
carbon-based energy sources;
increased demand
for services that result in lower emissions than competing
products;
increased
competition to develop innovative new services that result in lower
emissions; and
any anticipated
reputational risks resulting from operations or products that produce
material greenhouse
gas emissions.
2. Disclose the material
effects of transition risks related to climate change that may affect
your business,
financial condition, and results of operations, such as policy and regulatory
changes that could
impose operational and compliance burdens, market trends that may
alter business
opportunities, credit risks, or technological changes.
Qimin Zhou
China Eastern Airlines Corporation Limited
September 17, 2021
Page 2
3. Disclose any material litigation risks related to climate change and
the potential impact to
the company.
4. Quantify any material increased compliance costs related to climate
change.
5. If applicable and material, provide disclosure about any purchase or
sale of carbon credits
or offsets and any material effects on your business, financial
condition, and results of
operations.
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.
You may contact Wei Lu, Staff Accountant at (202) 551-3725 or Brad
Skinner, Office
Chief at (202) 551-3489, if you have questions regarding the comments.
FirstName LastNameQimin Zhou Sincerely,
Comapany NameChina Eastern Airlines Corporation Limited
Division of Corporation
Finance
September 17, 2021 Page 2 Office of Energy &
Transportation
FirstName LastName