 From September 1938, the division came under the control of the IJA 21st Army, and participated in the Canton Operation and the invasion and occupation of Guangdong Province under the command of Lieutenant General Seiichi Kuno.The division remained in China through the 1939–40 Winter Offensive under the command of Lieutenant General Harukichi Hyakutake.From 6 November 1941 the division came under the command of Lieutenant-General Renya Mutaguchi and was reassigned to the IJA 25th Army (which was under the command of General Yamashita Tomoyuki).