View:
United States securities and exchange commission logo
June 30, 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
Filed March 17,
2023
File No. 001-37791
Dear Nik Jhangiani:
We have limited our review of your filing to the financial
statements and related
disclosures 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.
Form 20-F for the fiscal year ended December 31, 2022
Strategic Report, page 1
1. We note you present
several non-IFRS measures more prominently than the most directly
comparable IFRS
measures, for example on pages 1 and 8. Please fully comply with Item
10(e)(1)(i)(A) of
Regulation S-K in future Form 20-Fs.
2. We note you present a
non-IFRS measure you identify as ROIC; however, the numerator
of this measure appears
to be a non-IFRS measure and you do not present a measure based
on the most directly
comparable IFRS measure with equal or greater prominence. Please
revise the title of the
measure you present and fully comply with Item 10(e)(1)(i)(A) of
Regulation S-K in
future Form 20-Fs.
Nik Jhangiani
COCA-COLA EUROPACIFIC PARTNERS plc
June 30, 2023
Page 2
Business and financial review
Supplementary financial information - Income Statement - Reported to
Comparable, page 83
3. We note you present full non-IFRS income statements to reconcile
reported results to
"comparable" and "pro forma comparable" results on pages 83 and 84,
which appears to
give undue prominence to your non-IFRS measures. Please refer to
Question 102.10(c) of
the SEC's Compliance & Disclosure Interpretations on Non-GAAP
Financial Measures
and modify your presentations in future filings accordingly.
Consolidated Financial Statements
Note 7 - Intangible assets and goodwill
TCCC franchise intangible assets, page 170
4. We note your long-standing accounting policy and disclosures regarding
your treatment of
TCCC bottling agreement intangible assets as indefinite lived
intangible assets even
though they have a stated term of 10 years and contain a 10 year
renewal right. We also
note your policy may be inconsistent with other entities with similar
assets. Please refer
to paragraph 94 of IAS 38 and more fully explain to us why you believe
your accounting
policy is appropriate and consistent with IFRS, given the stated term
of the agreements.
In addition, please more fully explain to us the process and expected
costs of renewing
the agreements at the end of their 10 year term and how you concluded
renewals are
essentially perpetual in nature.
In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.
You may contact Kevin Stertzel at (202) 551-3723 or Anne McConnell at
(202) 551-
3709 with any questions.
FirstName LastNameNik Jhangiani Sincerely,
Comapany NameCOCA-COLA EUROPACIFIC PARTNERS plc
Division of Corporation Finance
June 30, 2023 Page 2 Office of Manufacturing
FirstName LastName