《老子河上公注》是我国古代第一部完整的注老之作 ,在我国老学研究史上 ,享有独特地位。但是对于这部著作的成书年代 ,一些研究者却将之拉得很后。有的认为它成书于魏晋葛洪时代 ,有的认为它成书于东汉中后期。这不但有违历史的真实 ,也大大削弱了该书应有的历史地位。对此 ,金春峰先生曾提出过西汉前期说 ,但未引起学界足够的重视。本文基本赞同金氏的意见 ,并从新的角度对之作了进一步论证 ,认为该书既不能晚至魏晋葛洪时代 ,也不能晚至东汉。从已知的材料推测 ,它很可能成书于西汉中期或稍前。 “Lao Tzu on the river” is the first complete ancient in our country in ancient China, in the history of the study of old Chinese, enjoy a unique position. But for the book’s book years, some researchers have pulled it very backward. Some think it was written in the Wei and Jin Ge Hong era, and some think it was written in the late Eastern Han Dynasty. This is not only contrary to the truth of history, but also greatly weakened the due historical status of the book. In response, Mr. Jin Chunfeng had put forward the early Western Han Dynasty said, but did not attract enough attention academia. This article basically agrees with King’s opinion and further argues it from a new perspective that this book can neither be late in the Wei and Jin Ge Hong era, nor late to the Eastern Han Dynasty. Speculated from the known material, it is likely to book in the mid-Western Han Dynasty or a little earlier.