October 10, 2024

Arthur Yu
Chief Financial Officer
Baozun Inc.
No. 1-9, Lane 510
West Jiangchang Road
Shanghai, China 200436

       Re: Baozun Inc.
           Form 20-F for the Fiscal Year Ended December 31, 2023
           Response dated September 3, 2024
           File No. 001-37385
Dear Arthur Yu:

        We have reviewed your September 3, 2024 response to our comment letter
and have
the following comment(s).

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

       After reviewing your response to this letter, we may have additional
comments.
Unless we note otherwise, any references to prior comments are to comments in
our August
6, 2024 letter.

Form 20-F for the Fiscal Year Ended December 31, 2023
Certain Defined Terms, page 1

1.     We note your revised disclosure that    we,       us,       our company,
   and    our,    refer to
       Baozun Inc., a Cayman Islands exempted company; however, throughout your
       disclosure, you use these terms to disclose operations by your VIE. For
example, you
       make the following statements:

             "We currently hold all material licenses and permits required for
our business
           operations, including a value -added telecommunication license, or a
VAT
           license, ..."(page 5);
              "Our ability to provide one-stop e-commerce solutions is
empowered by our
           proprietary and robust technology stack, including our Cloud-based
System that
 October 10, 2024
Page 2

           enables efficient setup of official brand stores and official
marketplace stores, ...
           "(page 68);
             "We believe our brand partners value us for our integrated
e-commerce
           capabilities, dependable services, deep category expertise, market
insight and
           ability to innovate and adapt to the fast-changing e-commerce
market." (page 70).

       Please note that this is not meant to represent an all-inclusive list of
where your
       disclosure should be revised to refrain from using terms such as    we
 or    our    when
       describing activities or functions of your VIE.
Our Corporate Structure and Contractual Arrangements with our VIE, page 3

2.     We note your response to comment 5 and reissue our comment in part.
Describe the
       relevant contractual agreements between you and the VIEs and how this
type of
       corporate structure may affect investors and the value of their
investment, including
       how and why the contractual arrangements may be less effective than
direct
       ownership and that the company may incur substantial costs to enforce
the terms of
       the arrangements.
Changes in the political and economic policies of the PRC government may
materially and
adversely affect our business, ..., page 43

3.     We note your proposed revised language in response to comment 19. We
reissue our
       comment in part, please revise your disclosure to disclose that given
recent statements
       by the Chinese government indicating an intent to exert more oversight
and control
       over offerings that are conducted overseas and/or foreign investment in
China-based
       issuers, acknowledge the risk that any such action could significantly
limit or
       completely hinder your ability to offer or continue to offer securities
to investors and
       cause the value of such securities to significantly decline or be
worthless.
       Please contact Scott Stringer at 202-551-3272 or Adam Phippen at
202-551-3336 if
you have questions regarding comments on the financial statements and related
matters. Please contact Scott Anderegg at 202-551-3342 or Taylor Beech at
202-551-4515
with any other questions.



                                                             Sincerely,

                                                             Division of
Corporation Finance
                                                             Office of Trade &
Services