June 15, 2018

Bin Li
Chief Executive Officer
NIO Inc.
Building 20, No. 56 AnTuo Road, Jiading District
Shanghai, 201804
People's Republic of China

       Re: NIO Inc.
           Amendment No. 1 to Draft Registration Statement on Form F-1
           Filed June 7, 2018
           CIK No. 0001736541

Dear Mr. Li:

      We have reviewed your amended draft registration statement and have the
comments. In some of our comments, we may ask you to provide us with
information so we
may better understand your disclosure.

       Please respond to this letter by providing the requested information and
either submitting
an amended draft registration statement or publicly filing your registration
statement on
EDGAR. If you do not believe our comments apply to your facts and circumstances
or do not
believe an amendment is appropriate, please tell us why in your response.

      After reviewing the information you provide in response to these comments
and your
amended draft registration statement or filed registration statement, we may
have additional

Amendment No. 1 to DRS on Form F-1

Risk Factors
Risk Relating to Our Business
Manufacturing in collaboration with partners is subject to risks, page 15

1.     We note your revised disclosure on page 15 that "for the first 36 months
after [the] agreed
       time of start of production, to the extent the Heifei manufacturing
plant incurs any
       operating losses, [you] have agreed to compensate JAC for such operating
losses." Please
       disclose the "agreed time of start of production" here.
 Bin Li
FirstName LastNameBin Li
NIO Inc.
Comapany NameNIO Inc.
June 15, 2018
June 15, 2018 Page 2
Page 2
FirstName LastName
Our vehicles are subject to motor vehicle standards, page 23

2.       We note your response to our prior comment 5 that the "ES6 and ET7
have not yet
         undergone CCC certification but must be certified prior to being
marketed." Please
         disclose when you intend to begin the CCC certification process for
the ES6 and the
         estimated amount of time it takes to receive such certification. In
this regard, we note that
         you plan to launch the ES6 by the end of 2018 and to start initial
deliveries in the first half
         of 2019.
Our business plans require a significant amount of capital , page 25

3.       We note your response to our prior comment 6 that "[your] future
capital requirements
         may be uncertain and actual capital requirements may be different from
those [you]
         currently anticipate. Please revise to disclose the capital
requirements you currently
         anticipate for your currently planned research and development,
expansion of your
         production capacity as well as the currently planned roll out of your
charging and
         servicing network and your NIO houses.
Our Power Solutions
Access to Public Charging, page 118

4.       We note your revised disclosure on page 118 regarding the public
superchargers. Please
         disclose what percentage of the 214 thousand publicly accessible
charging piles are
User Development and Branding
Other Branding Activities, page 126

5.       You disclose that since December 2016 you have sold over 343,000
pieces of
         merchandise through your online store. You also disclose you provide
users with NIO
         credits, the credits can be used at your online store and NIO Houses
to purchase
         merchandise and other items, and as of May 31, 2018 approximately 212
million NIO
         credits had been used at your online store. Please explain to us your
accounting for the
         merchandise sold through your online store and your accounting policy
for NIO credits,
         including any outstanding unredeemed credits. Also, tell us where the
merchandise sold
         and credits, both redeemed and unredeemed, are reported in your
financial statements and
         the amounts related thereto.
Manufacturing, Supply Chain and Quality Control
Our Future Manufacturing Plant, page 129

6.       We note your response to our prior comment 15 and reissue in part.
Please disclose the
         material terms of your lease of the manufacturing facility that is
currently being built in
 Bin Li
NIO Inc.
June 15, 2018
Page 3
         Shanghai as well as the current estimated costs of the improvements
you currently plan on
         making and the equipment you currently plan to purchase.
Certain Other Cooperation Arrangements, page 130

7.       Please disclose GAC NIO New Energy Vehicle Technology Co., Ltd.'s
current plans for a
         qualified initial public offering, if any, and please briefly discuss
what constitutes a
         "qualified initial public offering" under the GAC NIO New Energy
Vehicle Technology
         Co., Ltd. joint venture agreement. In addition, provide a brief
description of the "required
         reserves" pursuant to the Changan NIO Renewable Automobiles Co., Ltd.
joint venture
       You may contact Theresa Brillant at 202-551-3307 or Doug Jones at
202-551-3309 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Sonia Bednarowski at 202-551-3666 or Anne Nguyen Parker, Assistant
Director, at 202-
551-3611 with any other questions.

FirstName LastNameBin Li
Comapany NameNIO Inc.
                                                               Division of
Corporation Finance
June 15, 2018 Page 3                                           Office of
Transportation and Leisure
FirstName LastName