Exhibit 5.1

Re:  Registration Statement on Form S-1

Ladies and Gentlemen:

We have acted as counsel to Yum China Holdings, Inc., a Delaware corporation (the “Company”), in connection with the offer and sale of up to 10,000,000 shares of the Company’s common stock, $0.01 par value per share (the “Shares”), pursuant to the Company’s Long Term Incentive Plan (the “Plan”), as described in the Registration Statement on Form S-1, File No. 333-213719 (the “Registration Statement”), filed with the Securities and Exchange Commission (the “Commission”).

As counsel to the Company, we have examined originals or copies certified or otherwise identified to our satisfaction of the Plan, the Employee Matters Agreement in the form in which it was filed as Exhibit 10.3 to the Company’s Registration Statement on Form 10 dated as of September 16, 2016 (the “EMA”), the Company’s certificate of incorporation and the Company’s bylaws, each as amended, restated and supplemented, the resolutions of the board of directors of the Company and such records of the Company, certificates and other documents and such questions of law as we considered necessary or appropriate for purposes of this opinion. As to certain factual matters, we have relied, to the extent we deem such reliance proper, upon certificates of public officials and officers of the Company. In rendering this opinion, we have assumed the genuineness of all signatures, the authenticity of all documents submitted to us as originals and the conformity to authentic original documents of all documents submitted to us as copies.

Subject to the foregoing, we are of the opinion that the Shares have been duly authorized for issuance and, when issued in conformity with the provisions of the Plan and the EMA, will be validly issued, fully paid and nonassessable.

The opinion expressed above is limited to the Delaware General Corporation Law and we express no opinion with respect to any other laws.

The opinion expressed herein is as of the date of this letter. We assume no obligation to update or supplement this letter to reflect any facts or circumstances that may hereafter come to our attention or any change in applicable law that may hereafter occur.

Mayer Brown LLP operates in combination with other Mayer Brown entities with offices in Europe and Asia
and is associated with Tauil & Chequer Advogados, a Brazilian law partnership.

We consent to your filing this opinion as an exhibit to the Registration Statement.  In giving such consent, we do not thereby admit that we are in the category of persons whose consent is required under Section 7 of the Securities Act of 1933, as amended, or the rules and regulations of the Commission thereunder.

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