Its first division commander was Lieutenant General Matsuura Junrokuro, a graduate from Japanese Army War College.

During August 1938, it advanced along railroad to Nanxun District,[2] and in September 1938 was heavily engaged in the Battle of Wanjialing.

The 106th artillery regiment was stuck in mountainous terrain, therefore was unable to provide any fire support from 20 September 1938, and entire division suffered heavy losses after its parts has been encircled in Lianxi District.

Five of the eight regiments were routed 24 September - 13 October 1938, and division suffered an 11,164 casualties (over half of total strength).

Instead it was assigned to the 21st army and sent to hold positions along the south bank of the Yangtze River between Wuhu and Hukou and stood off the attacks of the Chinese.