IPO News | Zhoulong Technology plans to list Hong Kong stocks, China Securities Regulatory Commission requires additional explanation on whether the use of capital raised this time involves overseas investment

Zhitong Finance App learned that on December 26, the China Securities Regulatory Commission announced the “Requirements for Supplementary Materials for Overseas Issuance and Listing Filing (December 22, 2025 to December 26, 2025)”. The International Department of the China Securities Regulatory Commission announced supplementary material requirements for 19 companies. Among them, Zhoulong Technology was requested to further explain whether the use of the funds raised this time involves overseas investment and whether relevant approval, approval or filing procedures have been carried out. According to reports, Zhoulong Technology submitted its listing to the Hong Kong Stock Exchange on October 30, 2025, with CITIC Securities and CITIC Construction Investment International as co-sponsors.

The China Securities Regulatory Commission requested Zhoulong Technology to further explain the following matters, and ask lawyers to check and issue clear legal opinions:

1. Please explain the transferor's income tax payments relating to the company's 17th, 18th, and 19th share transfers in August 2025 and the 21st share transfers in September 2025.

2. Please indicate whether the company's current use of capital raised involves overseas investment, and whether it has completed the relevant approval, approval or filing procedures.

3. Please explain the development and operation of products such as apps, applets, and public accounts by the company and its subsidiaries, and whether they involve the collection and use of personal information. If so, please indicate the scale of collected and stored user information and data collection and use.

4. Please explain the progress of the company's state-owned shareholder identification procedures.

5. Regarding foreign investment access: (1) The business scope of the company and its subsidiaries includes “agricultural scientific research and experimental development”, “second-level protected sturgeon” and fishery seedlings related businesses. Please explain the relevant business development and compliance, and explain the clear basis for not involving the fields related to foreign investment entry; (2) In addition to the above, please further explain whether the business scope and actual business operations of the company and its subsidiaries involve the “Special Administrative Measures for Foreign Investment Access (Negative List)” (2024 edition)”.

6. Please explain whether the shares held by shareholders who intend to participate in the “full circulation” have been pledged, frozen, or have other rights defects.

According to the prospectus, Sturgeon Technology is the world's largest caviar company. According to Insight Consulting, the company has achieved the number one caviar sales worldwide for 10 consecutive years since 2015. From 2021 to 2024, its caviar sales continued to account for more than 30% of the global market, reaching 35.4% in 2024, more than 5 times that of the second-largest company. The company founded the world-famous caviar brand “KALUGA QUEEN (KALUGA)”.