United States securities and exchange commission logo

                              February 2, 2023

       Joey Wat
       Chief Executive Officer
       Yum China Holdings, Inc.
       7100 Corporate Drive
       Plano, Texas 75024

                                                        Re: Yum China Holdings,
                                                            Form 10-K for the
Year Ended December 31, 2021
Filed January 3, 2023
                                                            File No. 1-37762

       Dear Joey Wat:

               We have reviewed your January 3, 2023 response to our comment
letter and have the
       following comment. In our comment, we may ask you to provide us with
information so we may
       better understand your disclosure.

              Please respond to this 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 this comment, we may have
       comments. Unless we note otherwise, our references to prior comments are
to comments in our
       December 16, 2022 letter.

       Correspondence Filed January 3, 2023

       Item 1A. Risk Factors, page 9

   1.                                                   We note your response
to comment 10. Revise to state whether you believe that you are
                                                        compliant with the
regulations or policies that have been issued by the CAC to date,
                                                        notwithstanding the
various uncertainties you disclose. In this regard, we are not aware of
                                                        any regulatory process
in which you are expected to be identified as a "critical information
operator" before ensuring compliance with the Revised Cybersecurity
                                                        Review Measures.
 Joey Wat
Yum ChinaLastNameJoey
          Holdings, Inc. Wat
February  2023      China Holdings, Inc.
Page 2 2, 2023 Page 2
FirstName LastName
       Please contact Taylor Beech at 202-551-4515 or Mara Ransom at
202-551-3264 with any


                                                       Division of Corporation
                                                       Office of Trade &
cc:      Lindsey Smith, Esq.