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September 18, 2023
Nik Jhangiani
Chief Financial Officer
COCA-COLA EUROPACIFIC PARTNERS plc
Pemberton House, Bakers Road
Uxbridge UB8 1EZ
United Kingdom
Re: COCA-COLA
EUROPACIFIC PARTNERS plc
Form 20-F for the
fiscal year ended December 31, 2022
Responses Dated
August 16 & 18, 2023
File No. 001-37791
Dear Nik Jhangiani:
We have reviewed your August 16, 2023 and August 18, 2023,
responses to our comment
letter and have the following comments. In some of our comments, we may
ask you to provide
us with information so we may better understand your disclosure.
Please respond to these comments within ten business days by
providing the requested
information or advise us as soon as possible when you will respond. If
you do not believe our
comments apply to your facts and circumstances, please tell us why in
your response.
After reviewing your response to these comments, we may have
additional
comments. Unless we note otherwise, our references to prior comments are
to comments in our
August 2, 2023 letter.
Form 20-F filed March 17, 2023
Consolidated Financial Statements
Note 7 - Intangible assets and goodwill
TCCC franchise intangible assets, page 170
1. In order for us to more
fully evaluate your accounting for the TCCC franchise intangible
assets, please provide
the following additional information:
We note others
entities in the Coca-Cola bottling system have bottling agreements
with TCCC that
appear to include successive 10 year renewal options. Explain why
your agreements
did not include successive renewal options.
In regard to your
intention to extend, amend or replace the contracts with TCCC, tell
us whether you
expect any other terms and conditions in the contracts to change or if
Nik Jhangiani
COCA-COLA EUROPACIFIC PARTNERS plc
September 18, 2023
Page 2
the only change you anticipate relates to extending the terms of
the contracts.
Tell us if you have any written or verbal agreements with TCCC
that demonstrate
both parties' intent to extend the current contractual terms
beyond the 20
years stipulated in the contracts or to replace the current
contracts at the end of their
20 year terms with new contracts with the same terms.
Tell us what, if any, history you have of amending your
contracts or entering into
new contracts with TCCC prior to 2016.
Explain how the intangible asset was recorded, including
whether the entire balance
was recorded as a result of your accounting for business
combinations.
In regards to your contracts with TCCC, tell us if you record
separate intangible
assets related to each territory or explain how the intangible
asset is allocated to each
territory. If applicable, tell us to the extent to which a few
territories comprise the
majority of the intangible asset balance.
You may contact Kevin Stertzel at (202) 551-3723 or Anne McConnell at
(202) 551-
3709 if you have questions regarding these comments.
FirstName LastNameNik Jhangiani Sincerely,
Comapany NameCOCA-COLA EUROPACIFIC PARTNERS plc
Division of Corporation Finance
September 18, 2023 Page 2 Office of Manufacturing
FirstName LastName