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                              June 15, 2020

       Kobi Altman
       Chief Financial Officer
       ICL Group Ltd.
       Millennium Tower
       23 Aranha Street
       P.O. Box 20245
       Tel Aviv, 61202 Israel

                                                        Re: ICL Group Ltd.
                                                            Form 20-F for
Fiscal Year Ended December 31, 2019
                                                            Filed March 5, 2020
                                                            File No. 001-13742

       Dear Mr. Altman:

             We have reviewed your filing and have the following comment. In
our comment, we
       may ask you to provide us with information so we may better understand
your disclosure.

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

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

       Form 20-F for Fiscal Year Ended December 31, 2019

       Note 3   Significant Accounting Policies
       K. Revenue Recognition, page F-31

   1.                                                   Please expand your
disclosure to provide company-specific information for your
                                                        performance
obligations, including (a) the nature of the goods or services promised; (b)
                                                        the timing of when you
recognize revenue (i.e., point in time or over time); and (c) the
                                                        typical payment terms.
Also, provide disclosures for each type of variable consideration
                                                        included in the
transaction price and the significant judgements used in the application of
                                                        IFRS 15.
               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.
 Kobi Altman
ICL Group Ltd.
June 15, 2020
Page 2

       You may contact Tracey Houser at 202-551-3736 or Jeanne Baker at
202-551-3691, if
you have questions regarding comments on the financial statements and related
matters.



FirstName LastNameKobi Altman                           Sincerely,
Comapany NameICL Group Ltd.
                                                        Division of Corporation
Finance
June 15, 2020 Page 2                                    Office of Life Sciences
FirstName LastName