United States securities and exchange commission logo





                              September 14, 2023

       Tracey T. Travis
       Chief Financial Officer
       The Est  e Lauder Companies Inc.
       767 Fifth Avenue
       New York, New York 10153

                                                        Re: The Est  e Lauder
Companies Inc.
                                                            Annual Report on
Form 10-K for the year ended June 30, 2023
                                                            Filed August 18,
2023
                                                            File No. 001-14064

       Dear Tracey T. Travis:

              We have reviewed your filing 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.

       Annual Report on Form 10-K for the year ended June 30, 2023

       General

   1.                                                   We note that you
provided more expansive disclosure in your Fiscal 2022 Social Impact
                                                        and Sustainability
Report ("SIS Report") and Climate Transition Plan 2022 ("CT
                                                        Plan") than you
provided in your SEC filings. Please advise us what consideration you
                                                        gave to providing the
same type of climate-related disclosure in your SEC filings as you
                                                        provided in your SIS
Report and CT Plan.
       Management's Discussion and Analysis of Financial Condition and Results
of Operations, page
       28

   2.                                                   To the extent material,
discuss the indirect consequences of climate-related regulation or
                                                        business trends, such
as the following:

                                                              decreased demand
for products or services that produce significant greenhouse gas
 Tracey T. Travis
The Est  e Lauder Companies Inc.
September 14, 2023
Page 2
              emissions or are related to carbon-based energy sources;
                increased demand for products or services that result in lower
emissions than
              competing products;
                increased competition to develop innovative new products that
result in lower
              emissions;
                increased demand for generation and transmission of energy from
alternative energy
              sources; and
                any anticipated reputational risks resulting from operations or
products that produce
              material greenhouse gas emissions.
3.       We note discussion in your SIS Report and CT Plan addressing climate
related-risks,
         including risks related to chronic heat, extreme weather, and
flooding. Please discuss the
         physical effects of climate change on your operations and results.
This disclosure may
         include the following:

                severity of weather, such as floods, hurricanes, sea levels,
extreme fires, and water
              availability and quality;
                quantification of weather-related damages to your property or
operations;
                potential for indirect weather-related impacts that have
affected or may affect your
              major customers or suppliers;
                decreased agricultural production capacity in areas affected by
drought or other
              weather-related changes; and
                the extent to which extreme weather events have reduced the
availability of insurance
              or increased the cost of insurance.

         Include quantitative information for each of the periods covered by
your Form 10-K and
         explain whether increased amounts are expected in future periods.
4.     You reference the use of carbon offsets, renewable energy credits
("RECs"), and energy
       attribute certificates ("EACs") in your SIS Report. Please provide
disclosure about your
       purchase or sale of carbon credits, offsets, RECs, or EACs and any
material effects on
FirstName LastNameTracey T. Travis
       your business, financial condition, and results of operations. This
disclosure should
Comapany    NameThe
       include          Est  e information
                quantitative   Lauder Companies
                                          for eachInc.
                                                   of the periods covered by
your most recent Form
       10-K  and  the amounts
September 14, 2023 Page 2       budgeted  for or expected to be incurred in
future periods.
FirstName LastName
 Tracey T. Travis
FirstName  LastNameTracey
                  CompaniesT.Inc.
                               Travis
The Est  e Lauder
Comapany 14,
September  NameThe
               2023 Est  e Lauder Companies Inc.
September
Page 3     14, 2023 Page 3
FirstName LastName
        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 Benjamin Richie at 202-551-7857 or Jennifer Angelini at
202-551-3047
with any other questions.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of Industrial
Applications and
                                                          Services