UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-5546 DIVISION OF CORPORATION FINANCE Mail Stop 5546 September 27, 2006 Via Facsimile (65) 6226 0502 and US Mail Philip Ting Sii Tien Chief Financial Officer China Yuchai International Limited 16 Raffles Quay #26-00 Hong Leong Building Singapore 048581 Re: China Yuchai International Limited Form 20-F Filed July 15, 2005 Response Letters Dated August 4, 2006 and September 7, 2006 File No. 1-13522 Dear Mr. Tien: We have reviewed your response dated September 7, 2006 and have the following comment. Please be as detailed as necessary in your response. After reviewing this information, we may raise additional comments. General 1. We note your response to prior comment two. Please confirm, if true, that Xinfei conducts its North Korean operations independent of you and your employees, and that Xinfei`s North Korean expenses and revenues do not affect your expenses and revenues. If, however, you or your subsidiaries` operations are affected by Xinfei`s North Korean operations, please discuss such overlapping or interrelated operations and expand your materiality analysis to take into account the North Korean contacts. For example, if you or your subsidiaries` operations are affected by Xinfei`s North Korean operations, express revenues from those operations as a percentage of your own total sales revenues, instead of as a percentage of Xinfei`s total sales revenues, and identify the significant factors underlying your conclusion that such North Korean contacts are qualitatively immaterial. Please respond to this comment within 10 business days or tell us when you will provide us with a response. Please file your response letter on EDGAR. Please contact James Lopez at (202) 551- 3536 if you have any questions about the comments or our review. You may also contact me at (202) 551-3470. Sincerely, Cecilia D. Blye, Chief Office of Global Security Risk cc: Peggy Fisher Assistant Director Division of Corporation Finance Philip Ting Sii Tien China Yuchai International Limited Page 1