January 18, 2008


Mr. Rufus Decker
Accounting Branch Chief
Division of Corporate Finance
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C.  20549

Re: International Flavors & Fragrances Inc.
     File Reference 001-4858
     Form 10-K for the year ended December 31, 2006
     Form 10-Q for the period ended June 30, 2007
     Proxy Statement on Schedule 14A

Dear Mr. Decker:

The Company is furnishing the following  supplementary  information and comments
with reference to the matters and questions raised in your letter dated December
19, 2007. The items below  correspond to the matters raised in your letter;  the
questions  raised  by the  Commission  have  been  repeated,  and the  Company's
response immediately follows.

FORM 10-K FOR THE YEAR ENDED  DECEMBER  31,  2006  Management's  Discussion  and
- --------------------------------------------------------------------------------
Analysis of Financial  Condition  and Results of Operations  Operating  Results,
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page 23
- -------

     1.   We note your  response  to comment 4 and the  proposed  future  filing
          disclosures  presented  in  Appendix I of your  letter.  It is unclear
          whether  the  proposed  future  filing  disclosures  are  intended  to
          represent your entire  analysis of operating  results for each segment
          or if you  intentionally  provided  only a  portion  of your  intended
          future  filing  disclosures.  We  would  expect  that a  comprehensive
          segment  analysis  would include a discussion of sales,  cost of goods
          sold,  gross  profit,  research  and  development  costs,  selling and
          administrative  expenses and any other significant financial statement
          line items  separately  for each segment.  Please  provide us with the
          revised MD&A segment  analysis  disclosures for 2006 compared to 2005,
          which will appear in your 2007 Form 10-K.

Company Response:
- ----------------
Our 2007 Form 10-K will include the MD&A segment  analysis  disclosures for 2006
compared to 2005 as presented in Appendix 1 to this response.  Our  accompanying
response addresses the operating  results;  commentary on sales will continue to
be addressed in a separate section of the MD&A.



PROXY  STATEMENT ON SCHEDULE 14A,  FILED MARCH 23, 2007  Executive  Compensation
- --------------------------------------------------------------------------------
Discussion & Analysis, page 36
- ------------------------------

     2.   Please  confirm that you will  disclose the  information  set forth in
          your responses to comments 17 and 18 in future proxy statements.

Company Response:
- ----------------
The Company  confirms  that it will disclose  such  information  in future proxy
statements.

                             **********************

If you require  additional  clarification  on any of the foregoing  responses or
have any additional comments, please contact me at 212-708-7145.

In connection with responding to your comments, the Company acknowledges that:

     -    The  Company is  responsible  for the  adequacy  and  accuracy  of the
          disclosure in its filings;
     -    Staff  comments or changes to disclosure in response to staff comments
          do not foreclose the Commission from taking any action with respect to
          the filing; and
     -    The  Company  may  not  assert  staff  comments  as a  defense  in any
          proceeding initiated by the Commission or any person under the federal
          securities laws of the United States.

                                                     Yours very truly,

                                                     /s/ Douglas. J. Wetmore
                                                     -------------------------
                                                     Douglas J. Wetmore
                                                     Senior Vice President and
                                                     Chief Financial Officer




                                                                  Appendix I

Item 2.  Management's  Discussion  and  Analysis  of Results of  Operations  and
Financial Condition

Operating Results

The relationship of cost of goods sold and other operating expenses to net sales
was as follows:



                                                    December 31,
                                        -------------------------------------
                                           2007        2006          2005
                                        -----------  ----------   ----------
                                                              
Costs of Goods Sold                         %          57.8%         58.6%
Research and Development Expenses           %           8.9%          9.0%
Selling and Administrative Expenses         %          16.8%         17.0%


     2006 in Comparison to 2005

     Cost of goods sold,  as a  percentage  of sales,  decreased 80 basis points
compared with 2005, mainly as a result of the improved sales performance leading
to better  absorption of manufacturing  expenses,  and favorable product mix. We
also  benefited  from the  elimination  of 69  manufacturing  positions in 2005,
mainly in North America and Europe, which resulted in savings of $4 million. The
average cost of raw materials increased 2%-3% over the prior year.


     Research  and  Development  expenses  were 8.9% of sales,  in-line with our
objective of spending 9% of revenues on research and development annually.


     Selling and  Administrative  expenses were 16.8% of sales compared to 17.0%
in  2005.  The  2005  results   included  $8  million   relating  to  a  product
contamination  matter;  2006 results  reflect a benefit of $3 million  insurance
recovery related to this contamination matter. We benefited from the elimination
of 129 positions,  mainly in North America and Europe, which resulted in savings
of  $8  million.  The  2006  period  also  includes  $31  million  in  incentive
compensation  expense  driven by improved sales and operating  performance;  the
2005 results included $5 million of such expense.

     Interest Expense

     Interest  expense  totaled  $26  million  and $24 million in 2006 and 2005,
respectively.  The average interest rate remained at 3.3% in for both years. The
interest  rate for each period  reflects our debt and interest  rate  management
plans.  Additional  details  are  contained  in  Note  X,  of the  Notes  to the
Consolidated Financial Statements.

     Other (Income) Expense, Net

     Other  (income)  expense,  net was $10  million  of  income  in 2006 and $3
million of expense in 2005. In 2006,  income  resulted from gains on asset sales
of  $18  million,   partially   offset  by  higher  exchange  losses  and  other
non-operating  expenses.  In 2005, income resulted primarily from exchange gains
and higher levels of interest  income earned on higher cash  balances.  Exchange
(losses)  or  gains  were  $(7)  million  and  $3  million  in  2006  and  2005,
respectively.  The exchange losses in 2006 were mainly the result of having U.S.
dollar  positions in Europe and Latin America which resulted in exchange  losses
upon the  weakening  of the U.S.  dollar  in  comparison  to the Euro and  other
currencies.


     Income Taxes

     The effective tax rate for 2006 was 27.7% and 21.6% for 2005. Our effective
tax rate  fluctuates  as a  result  of  earnings  in the  countries  in which we
operate.  The 2005 rate was  significantly  reduced as a result of a tax benefit
associated  with the American Jobs Creation Act ("AJCA"),  which  provided for a
special  one-time  tax  deduction  of  85% of  dividends  received  on  eligible
repatriated  foreign  earnings.  Tax  expense in 2005  reflects a benefit of $25
million  relating to our  repatriation  of $242 million of  dividends  under the
provisions of AJCA.  Excluding the benefit,  of AJCA, the effective tax rate for
2005 would have been 31.6%.

Operating Results by Business Unit

We evaluate the  performance of business units based on operating  profit before
gains/losses  on the  disposition  of assets,  interest  expense,  other  income
(expense),net,  Restructuring  and other charges and income taxes. See Note X to
our  Financial  Statements  for the  reconciliation  to Income  before  taxes on
income.

Flavors

Flavors  operating  profit of $153 million or 17.1%,  as a percentage  of sales,
increased  as  compared  to $114  million  or 13.3% in  2005.  The 2005  results
included $8 million  relating to a product  contamination  matter;  2006 results
reflect  a  benefit  of  a  $3  million  insurance   recovery  related  to  this
contamination  matter. The 2005 results also include approximately $6 million of
restructuring  charges. This profitability  improvement was partially the result
of  increased  sales  volume  leading  to  better  absorption  of  manufacturing
expenses,  and  favorable  product  mix.  Selling  and  administrative  expenses
declined substantially from 2005 largely as a result of a reduction in headcount
related to the  restructuring  more fully  described  below,  while research and
development expenses remained constant with 2005.  Offsetting the benefit of the
headcount  reduction  was  approximately  a $6  million  increase  in  incentive
compensation as a result of improved operating results.

Fragrances

Fragrance  operating  profit of $212  million  increased  from the $187  million
reported in 2005,  with a  corresponding  increase  in  operating  profit,  as a
percentage  of sales,  to 17.7% in 2006  from  16.4% in 2005.  The 2005  results
included  approximately  $10  million in  restructuring  charges  compared to $3
million  in  2006.   Higher  sales  volume  led  to  increased   absorption   of
manufacturing expenses,  which was partially offset by higher raw material costs
resulting  in  improved  profitability.  Spending on  research  and  development
remained fairly constant between the two years while selling and  administrative
expenses  declined  as a  result  of  the  headcount  reduction  related  to the
restructuring discussed below. Offsetting the benefit of the headcount reduction
was  approximately a $10 million increase in incentive  compensation as a result
of improved operating results.

Global Expenses

The  Global  expense  caption  represents  corporate  and   headquarters-related
expenses which include legal, finance,  human resources and other administrative
expenses that are not allocated to individual  business unit, as well as gain on
sale of businesses and other assets.  Global expenses increased by $9 million in
2006 over  2005,  primarily  due to  approximately  $11  million  of  additional
incentive  compensation  in 2006.  2005 Global  expenses  included $7 million in
restructuring charges.