Mail Stop 4628 February 1, 2019 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 refer you to our comment letter dated November 30, 2018, regarding business contacts with Syria and Sudan. We have completed our review of this subject matter. 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. Sincerely, /s/ Cecilia Blye Cecilia Blye, Chief Office of Global Security Risk cc: Amanda Ravitz Assistant Director