United States securities and exchange commission logo
August 2, 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
Response Dated July
14, 2023
File No. 001-37791
Dear Nik Jhangiani:
We have reviewed your July 14, 2023 response 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
June 30, 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 your response to
prior comment 4 you indicate that the TCCC bottling agreements have
a maturity date (with a
renewal period) and contain no automatic right of renewal. Please
provide us the actual
duration terms stipulated in your TCCC bottling agreements,
including maturity
dates and renewal periods. In addition, please more fully explain to us
how the renewal term
operates, including whether your TCCC bottling agreements
provide for successive
renewal periods.
Nik Jhangiani
COCA-COLA EUROPACIFIC PARTNERS plc
August 2, 2023
Page 2
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
August 2, 2023 Page 2 Office of Manufacturing
FirstName LastName