Mail Stop 4628

                                                             November 30, 2018

Via Facsimile
Phung Khong Fock Thomas
Chief Financial Officer
China Yuchai International Ltd.
16 Raffles Quay
#39-01A Hong Leong Building
Singapore 048581

       Re:     China Yuchai International Ltd.
               Form 20-F for the Fiscal Year Ended December 31, 2017
               Filed April 16, 2018
               File No. 1-13522

Dear Mr. Phung Khong Fock Thomas:

        We have limited our review of your filing to your contacts with
countries that have been
identified as state sponsors of terrorism, and we have the following comments.
Our review with
respect to this issue does not preclude further review by the Assistant
Director group with respect
to other issues. In our comment, we ask you to provide us with information so
we may better
understand your disclosure.

       Please respond to the comment 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
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to the comment, we may have additional
comments.

General

   1. In your letter to us dated July 8, 2015, you discussed contacts with
Syria and Sudan.
      Guangxi Yuchai Machinery's website provides contact information for Syria
under its
      Saudi Arabia office and for Sudan under its Egypt Office. As you know,
Syria and Sudan
      are designated by the U.S. Department of State as state sponsors of
terrorism and are
      subject to U.S. sanctions and/or export controls. Your Form 20-F does not
provide
      disclosure about those countries. Please describe to us the nature and
extent of any past,
      current, and anticipated contacts with Syria and Sudan since the 2015
letter, including
      with their governments, whether through subsidiaries, distributors,
resellers, affiliates, or
      other direct or indirect arrangements. Please also discuss the
materiality of any contacts,
      in quantitative terms and in terms of qualitative factors that a
reasonable investor would
 Phung Khong Fock Thomas
China Yuchai International Ltd.
November 30, 2018
Page 2

       deem important in making an investment decision. Tell us the approximate
dollar
       amounts of any revenues, assets and liabilities associated with Syria
and Sudan for the
       last three fiscal years and the subsequent interim period. Please
discuss the investor
       sentiment evidenced by divestment and similar initiatives directed
toward companies that
       have operations associated with U.S.-designated state sponsors of
terrorism.

        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 Jennifer Hardy, Special Counsel, at (202) 551-3767 or
me at (202) 551-
3470 if you have any questions about the comments or our review.

                                                          Sincerely,

                                                          /s/ Cecilia Blye

                                                          Cecilia Blye, Chief
                                                          Office of Global
Security Risk

cc:    Amanda Ravitz
       Assistant Director