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                            March 13, 2024

       Melissa N. Schaeffer
       Senior Vice President and Chief Financial Officer
       Air Products & Chemicals, Inc.
       1940 Air Products Boulevard
       Allentown, Pennsylvania 18106-5500

                                                        Re: Air Products &
Chemicals, Inc.
                                                            Form 10-K for
Fiscal Year Ended September 30, 2023
                                                            File No. 001-04534

       Dear Melissa N. Schaeffer:

              We have limited our review of your filing to the financial
statements and related
       disclosures and have the following comment.

              Please respond to this letter 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 a
       comment applies to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to this letter, we may have additional comments.

       Form 10-K for Fiscal Year Ended September 30, 2023

       5. Acquisitions, page 73

   1.                                                   Regarding the agreement
to purchase the natural gas-to-syngas processing facility in
                                                        Qashqadaryo Province,
Uzbekistan, for $1 billion, please provide us with a summary of
                                                        the material terms of
the agreement. Please also provide us with a summary of the analysis
                                                        you performed in
determining that the agreement should be accounted for as a financing
                                                        arrangement, including
the corresponding authoritative literature you considered. Please
                                                        specifically address
your initial accounting as well as ongoing accounting for this
                                                        transaction. Please
also address the need to expand your disclosures.



              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.
 Melissa N. Schaeffer
Air Products & Chemicals, Inc.
March 13, 2024
Page 2

       Please contact Tracey Houser at 202-551-3736 or Nudrat Salik at
202-551-3692 with any
questions.



                                                         Sincerely,
FirstName LastNameMelissa N. Schaeffer
                                                         Division of
Corporation Finance
Comapany NameAir Products & Chemicals, Inc.
                                                         Office of Industrial
Applications and
March 13, 2024 Page 2                                    Services
FirstName LastName