Shenzhen Securities Exchange:
We acknowledge receipt of the "Second Round of Review Inquiry Letter regarding Shenzhen HCD Technology Co., Ltd.'s Application for Issuance of Convertible Bonds to Unspecified Targets" (Review Letter [2026] 020004) issued by your exchange on January 22, 2026. Shenzhen HCD Technology Co., Ltd., along with Zheshang Securities Co., Ltd., Kangda Law Firm, and Zhongshen Certified Public Accountants (Special General Partnership), have diligently investigated and addressed each issue raised in the second round of inquiry letter. We provide the following responses for your review.
Explanation of Reply Content, Format, and Supplementary Disclosures:
I. Unless otherwise specified, abbreviations or technical terms used in this reply are consistent with the definitions in the "Prospectus (Application Draft) for Shenzhen HCD Technology Co., Ltd.'s Issuance of Convertible Bonds to Unspecified Targets." In this reply, discrepancies between the sum of individual items and the total are due to rounding.
II. The font styles used in this reply report represent the following:
| Second Round Inquiry Letter Issue | Reply to the Second Round Inquiry Letter Issue | Revision, Amendment, or Supplement to the Reply to the Inquiry Letter Issue | Font Style |
|---|---|---|---|
| Bold | Bold (Bold) | ||
| KaiTi (Bold) | Songti (Not Bold) |
Issue One
According to the application documents, the current fundraising project has added new energy connectors and FPC products compared to the previous fundraising project. This re-launched project is directed towards the production lines that were not built according to the original plan due to a reduction in investment scale in the previous fundraising project. The reason for the reduction in investment scale for the previous "CCS and FPC Module Project for Power Battery and Energy Storage Battery Systems" was the dual changes in technological iteration and market demand, which revealed insufficient adaptability. Some of the equipment in the original plan was lagging behind industry-leading levels in terms of product size, energy efficiency, and automation. If built according to the original plan, the project would face the risk of insufficient product competitiveness upon production, making it difficult to meet customer requirements for high-end products.
The current fundraising project is designed with a production capacity of 5 million sets of CCS modules and 48 million new energy connectors per year. The company's capacity utilization rates for CCS modules and new energy connectors are 87.16%, 25.69%, and 69.26%, and 93.08%, 60.33%, and 57.26% respectively, indicating that the overall process is in the ramp-up phase. Products that have obtained certification and those currently in the sampling stage are expected to contribute 32.89% to the company's total revenue in 2026 after the project reaches full production.
Please provide supplementary explanations from the issuer: (1)结合前次募投项目变更原因、本次募投项目和前次的区别与联系、相关不利因素是否消除等,说明本次募投项目投向前次缩减规模项目的原因及合理性,本次募投项目产品是否具有市场竞争力。(2)结合产能利用情况,说明本次新增产能规模的合理性,能否有效消化。
Please disclose relevant risks from the issuer.
Please have the sponsor and the issuer's accountant conduct an audit and provide their explicit opinions.
Reply:
I. Regarding the reasons for the change in the previous fundraising project, the differences and connections between the current fundraising project and the previous one, and whether the relevant adverse factors have been eliminated, please explain the reasons and rationality for the current fundraising project's investment in the previously scaled-down project, and whether the products of the current fundraising project have market competitiveness.
(I) Reasons for the change in the previous fundraising project
The core reasons for the reduction in investment scale for the previous "CCS and FPC Module Project for Power Battery and Energy Storage Battery Systems" can be summarized into three dimensions: misalignment of strategic layout, asynchronous technological iteration, and incompatibility with customer demand. The specifics are as follows:
- Systematic Optimization of Company Strategy Upgrade and Production Layout