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                             August 25, 2022

       William McLain, Jr.
       Senior Vice President and Chief Financial Officer
       Eastman Chemical Company
       200 South Wilcox Drive
       Kingsport, TN 37662

                                                        Re: Eastman Chemical
Company
                                                            Form 10-K for the
Fiscal Year Ended December 31, 2021
                                                            Filed February 25,
2022
                                                            Form 10-Q for the
Fiscal Quarter Ended June 30, 2022
                                                            Filed August 1,
2022
                                                            File No. 001-12626

       Dear Mr. McLain:

              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 10-Q for the Fiscal Quarter Ended June 30, 2022

       Management's Discussion and Analysis of Financial Condition and Results
of Operations, page
       34

   1.                                                   In light of your
disclosure that the conflict between Russia and Ukraine has had a negative
                                                        impact on your earnings
before interest and taxes (EBIT), please address the following
                                                        points in future
filings, and provide us with proposed disclosure in your response:

                                                              Disclose any
material impact of import or export bans resulting from Russia   s
                                                            invasion of Ukraine
on any products or commodities, including energy from Russia,
                                                            used in your
business or sold by you. Disclose the current and anticipated impact on
                                                            your business,
taking into account the availability of materials, cost of materials,
                                                            costs and risks
associated with transportation in your business, and the impact on
 William McLain, Jr.
FirstName LastNameWilliam
Eastman Chemical  Company McLain, Jr.
Comapany
August 25, NameEastman
           2022        Chemical Company
August
Page 2 25, 2022 Page 2
FirstName LastName
              margins and on your customers.

                Disclose any known trends or uncertainties that have had or are
reasonably likely to
              have a material impact on your cash flows, liquidity, capital
resources, cash
              requirements, financial position, or results of operations
arising from, related to, or
              caused by the global disruption from, Russia   s invasion of
Ukraine. Trends or
              uncertainties may include impairments of financial assets or
long-lived
              assets; declines in the value of inventory, investments, or
recoverability of deferred
              tax assets; the collectability of consideration related to
contracts with customers; and
              modification of contracts with customers.
2.       In light of the significance of your activity in China, as well as
your disclosure on page 53
         about the uncertainty caused by lockdowns in China, please revise your
future filings
         to disclose the extent to which your business segments, products,
projects, or operations
         are materially impacted by the pandemic-related lockdowns in China and
the impact of
         consumer demand declines therein. In addition, discuss any steps you
are taking to
         mitigate adverse impacts to your business. Provide us with your
proposed disclosure.
Summary by Operating Segment
Fibers Segment, page 48

3.       We note your disclosure stating that your EBIT for the Fibers segment
decreased in the
         first six months 2022 compared to the first six months 2021 due to $33
million of lower
         sales volume and higher manufacturing costs, primarily as a result of
the steam line
         incident and the Russia/Ukraine conflict, partially offset by higher
selling prices offsetting
         higher raw material and energy costs, and higher distribution costs by
$13 million. Please
         address the following in your future filings, and provide us with your
proposed
         disclosure:

                Expand your disclosure to separately quantify the decrease in
EBIT caused by the
              steam line incident and the Russia/Ukraine conflict, and disclose
the specific manner
              in which the Russia/Ukraine conflict has reduced demand for your
products and
              increased the manufacturing costs in this segment.

                You also disclose that for the second quarter 2022 compared to
second quarter 2021,
                 Higher selling prices more than offset higher raw material and
energy costs and
              higher distribution costs. This was offset by lower sales volume
and higher
              manufacturing costs primarily as a result of the steam line
incident and the
              Russia/Ukraine conflict.    However, elsewhere on page 39 you
disclose that all areas
              of the Kingsport facility were operational by March 31, 2022.
Revise your
              disclosure to more clearly quantify the impact of the steam line
incident during the
              second quarter 2022 as well as the impact from the Russia/Ukraine
conflict on second
              quarter EBIT.
Risk Factors
 William McLain, Jr.
Eastman Chemical Company
August 25, 2022
Page 3
Risks Related to Global Economy and Industry Conditions, page 54

4.       We note your risk factor disclosure indicating that inflation could
adversely impact both
         the cost and availability of raw material and energy commodities as
well as the sales your
         products. In future filings, please update this risk factor to
disclose the extent to which
         recent inflationary pressures have materially impacted your
operations. In this regard,
         identify the types of inflationary pressures you are facing, the
specific raw materials and
         energy commodities impacted, and how your business has been affected.
Identify and
         discuss your specific approaches to mitigating the impact of
inflation, disclosing the
         degree to which those approaches have been successful in mitigating
its impact to date as
         well as your expectations for the future. Provide us with your
proposed disclosure.
5.       We note your risk factor disclosure indicating that supply chain and
transportation
         disruptions, related to the pandemic and otherwise, and the breakdown
or degradation of
         transportation and supply chain infrastructure used for delivery of
strategic raw material
         and energy commodities and for transportation of your products could
adversely impact
         both the cost and availability of these commodities and sales of your
products. In future
         filings, please update the risk factor to more clearly disclose the
extent to which recent
         supply chain disruptions have materially impacted your operations. In
this regard, explain
         how supply chain disruptions have impacted your business and results
of operations,
         including how the disruption has come about, the specific raw
materials that were
         impacted, and the anticipated duration and cost of the disruption.
Provide us with your
         proposed disclosure.
       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 Tracie Mariner, Staff Accountant, at (202) 551-3744 or
Kevin Vaughn,
Branch Chief, at (202) 551-3494 with any questions.



FirstName LastNameWilliam McLain, Jr.                          Sincerely,
Comapany NameEastman Chemical Company
                                                               Division of
Corporation Finance
August 25, 2022 Page 3                                         Office of Life
Sciences
FirstName LastName