ELEstée Lauder Companies

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.

In response to the Staff’s comment, the Company advises the Staff that the Company’s Social Impact and Sustainability Report (“SIS Report”), as well as the Climate Transition Plan 2022 ("CT Plan"), are designed to provide selected voluntary information and are part of our overall communication regarding the Company’s social impact and sustainability activities to a broad group of stakeholders that includes consumers, investors, employees, retailers, suppliers and local communities, and are developed in accordance with, and is responsive to, relevant sustainability reporting standards and

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frameworks, including the Global Reporting Initiative (GRI) Standards, Task Force on Climate-related Financial Disclosures (TCFD) and Sustainability Accounting Standards Board (SASB). In contrast to the reporting standards used for our SIS Report and CT Plan, the current SEC disclosure requirements are primarily focused on providing material information to investors. As such, we approach how and what we disclose in our SIS Report and our SEC filings differently. As a result, the SIS Report and CT Plan may include detailed information, such as information regarding the Company’s efforts to reduce greenhouse gas (“GHG”) emissions, that is beyond the scope of the information that is required to be disclosed pursuant to applicable SEC rules and/or regulations. As noted in the SIS Report and the CT Plan, the use of the term "material" in the context of those reports is distinct from, and should not be confused with, the terms "material" or "materiality" under the securities laws and regulations. Therefore, matters considered to be material for purposes of those reports may not be considered material in the context of our consolidated financial statements and filings with the SEC, and the inclusion of information in those reports is not an indication that such information is necessarily material to the Company in those contexts.

When considering whether to include climate-related disclosure in its SEC filings, including the type of climate-related disclosure provided in the SIS Report and CT Plan, the Company takes into account applicable SEC rules and regulations, including Regulation S-K Item 101, Item 103, Item 105 and Item 303, as well as whether the information constituted “such further material information, if any, as may be necessary to make the required statements, in the light of the circumstances under which they were made, not misleading” pursuant to Rule 12b-20 under the Securities Exchange Act of 1934. The Company further considered the SEC’s Interpretive Release, Commission Guidance Regarding Disclosure Related to Climate Change (Release No. 33-9106).

While the initiatives and goals identified in the SIS Report and CT Plan were strategically important to the Company’s overall sustainability program at the time the report was published, the Company did not, and currently does not, believe these initiatives and their related financial impact rise to the level of materiality under the SEC’s rules, regulations and interpretive guidance noted above, either qualitatively or quantitatively. The climate-related initiatives identified in the SIS Report and CT Plan, to date, have not required material capital expenditures or operating expenses and the Company does not believe, at this time, that they are reasonably likely to have a material impact on future results of operations of the Company's liquidity and capital resources. Additionally, these initiatives have not caused significant operational challenges or material risks to the Company’s business, financial position, liquidity, capital resources or consolidated results of operations as further described in this response letter.

As it pertains to this question and the other questions below, as the Company’s investments and operational efforts to address emissions and climate change continue to evolve, the Company will continue to evaluate its disclosures in its future SEC filings based on the rules, regulations and interpretive guidance, and will update its disclosures as required.

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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 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

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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.

The Company considers applicable SEC disclosure rules, regulations, and guidance, as noted in Response 1 above, when preparing its SEC filings and, as applicable and to the extent material, evaluates disclosure regarding indirect consequences of climate-related regulation or business trends. As of the filing of the Form 10-K for the fiscal year ended June 30, 2023, the Company had not identified any material indirect consequences of climate-related regulation or business trends.

The Company manufactures, markets and sells makeup, skin care, fragrance and hair care products, for which demand

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is based on a number of factors, including the quality, efficacy and claims of our products. The use of our products does not produce significant greenhouse gas emissions. The Company did not identify and has not identified any significant changes in competition due to innovative new products that result in lower emissions based on the nature of our products.

With regard to increased demand for generation and transmission of energy from alternative energy sources, as more companies engage in sustainable activities demanding the use of alternative energy sources, we would expect the cost to increase initially unless matched by an increasing supply of such alternatives. However, we have taken actions to mitigate this risk such as through the installation of solar technology on certain of our owned and operated sites as well as through our Virtual Power Purchase Agreement for wind energy, as discussed in the SIS Report, for which costs to date have not been material.

With regard to the Company’s greenhouse gas emissions, as disclosed on page 8 of the SIS Report, we have achieved carbon neutrality across our Scope 1 and Scope 2 emissions and sourced 100% renewable electricity globally for our direct operations for fiscal 2022, 2021, and 2020. We have included additional goals and targets related to the reduction of greenhouse gas emissions within our operations in the SIS Report. To the extent we are unable to achieve these goals and targets, it may harm our reputation. This is consistent with the risk factor included in the fiscal 2023 Form 10-K “Our business could be negatively impacted by social impact and sustainability matters”. However, based on the progress on our goals to date and the metrics achieved as noted above, we have not experienced or identified any anticipated reputational risks resulting from operations or products that produce material greenhouse gas emissions.

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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.

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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.

The Company considers applicable SEC disclosure rules, regulations, and guidance, as noted in Response 1 above, when preparing its SEC filings and, as applicable and to the extent material, evaluates disclosure regarding any significant physical effects of climate change on its consolidated operations and results.

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As of the filing of the Form 10-K for the fiscal year ended June 30, 2023, the Company had not identified any significant physical effects of climate change on its consolidated operations and results that were material to the Company.

As background, the Company has a diverse geographical presence globally, which limits the risk of a severe climate related event having a material impact on the consolidated operations and results. Our products are sold in approximately 150 countries and territories, across various distribution channels including our own and authorized retailer websites, on third-party online malls, in stores in airports, in duty-free locations and in our own and authorized freestanding stores (we operated approximately 1,600 freestanding stores as of June 30, 2023). In addition, our products are sold in brick-and-mortar retail stores, including department stores, specialty-multi retailers, upscale perfumeries and pharmacies and prestige salons and spas. We have wholly owned operations in over 50 countries through which we market, sell and distribute our products. We have 34 principal owned and leased manufacturing, assembly, research and development and distribution facilities located in a number of countries around the world. We manufacture our products primarily in our own facilities in the United States, Belgium, Switzerland, the United Kingdom, Canada and Japan, and also leverage global third-party manufacturing networks. We have established a flexible global distribution network that is managed by us or third parties, and is designed to meet the changing demands of customers while maintaining service levels.

With regards to a potential indirect impact on our operations and results from a weather-related impact on our suppliers, we currently source more than 4,000 ingredients from hundreds of suppliers across the globe. The principal raw materials used in the manufacture of our products are essential oils, alcohols and specialist chemicals. We purchase packaging components that are manufactured to our design specifications. We also partner with an extensive and reliable network of third-party manufacturers that help us access innovation and capacity. Some of our products rely on single-source or a limited number of suppliers; however, we believe we have a robust business continuity strategy, sophisticated capacity planning tools and strategic inventory buffer and multi-sourcing solutions. Although it is rare, we have had instances where our direct material suppliers experienced temporary business impact due to weather-related events (e.g. hurricane, tornados, flood, excessive heat, etc.); however, the impact to the Company has not been material due to the business continuity processes in place within both the Company and at our suppliers (e.g. dual sources, safety stock, inventory levels, etc.), which have been able to avoid significant costs and lost net sales.

We also have a diverse set of customers globally, with no one customer constituting greater than 10% of our consolidated net sales for the fiscal year ended June 30, 2023, reducing the risk of a severe climate related event having a material impact on the consolidated operations and results.

As a result of the Company’s geographic and customer net sales diversity, manufacturing and distribution diversity, and supplier and ingredient diversity, local and regional climate change and weather-related events, such as floods, hurricanes, sea levels, extreme fires, and water availability and quality, have not materially adversely impacted, and are also not reasonably likely to have a material effect on, the Company’s consolidated operations and results in the near term. While these types of weather-related events have certainly occurred, they have not materially adversely impacted the Company’s financial performance or caused any material damages to the Company’s property or operations. For example, our most noteworthy cost impact has been from the impact of Superstorm Sandy in the United States, affecting our facilities in New York in 2012, resulting in less than $1 million in uninsured costs.

We have not experienced any material impacts to our insurance costs or to the availability of insurance due to weather-related factors. Rates across all lines of insurance have increased over the last three fiscal years due to general market wide price hardening driven by costs for extreme weather events, industry attrition losses, inflationary pressures on the cost of replacement valuations, and the reduction of available capacity in the insurance market. These industry wide effects have been partially mitigated as our property related insurable assets are not typically subject to extreme weather-related events and areas. We have also mitigated the rate effects through active risk management efforts in property protection programs on our portfolio. While we manage the insurance portfolio to maximize efficiency on the premium spend, the costs of the property-related premiums are not material, representing approximately 0.2% of selling, general and administrative expenses in fiscal 2023, 2022, and 2021. For the near term future, we do not expect weather-related factors to affect our ability to obtain property related insurance coverage or to increase the cost of property related insurance coverage to an extent that would be material to the Company.

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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 your business, financial condition, and results of operations.

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This disclosure should include quantitative information for each of the periods covered by your most recent Form 10-K and the amounts budgeted for or expected to be incurred in future periods. 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.

The Company considers applicable SEC disclosure rules, regulations, and guidance, as noted in Response 1 above, when preparing its SEC filings and, as applicable and to the extent material, evaluates disclosure regarding the use of carbon offsets, renewable energy credits, and energy attribute certificates.

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For the periods covered by and as of the filing of the Form 10-K for the fiscal year ended June 30, 2023, the Company had not identified any material uses that warrant disclosure.

In fiscal 2023, 2022, and 2021, we purchased a total of approximately $1 million in each year in carbon offsets and RECs/EACs. Currently, we do not expect purchases in fiscal 2024 to materially exceed our historical levels, nor do we expect that future purchases will materially affect our business, financial condition, and consolidated results of operations.

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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.

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We note your response to prior comment 2. Please further address the following: • Tell us more about the climate-related changes in demand and competition you have experienced for your products, including in relation to product packaging, sourcing, and formulation.

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Include an explanation of how you determined whether such changes are due to the factors identified in your response or due to climate-related factors, and how you assessed materiality, providing support for you determination. • Clarify whether your SIS goals and targets (e.g., carbon neutrality across Scope 1 and Scope 2 emissions and sourcing 100% renewable energy for your direct operations) are related to changes in demand and competition for products that result in lower greenhouse gas emissions, are not derived from carbon-based sources, and/or are produced using alternative energy sources. In this regard, we note disclosure of page 12 of your Form 10-K that, “There continues to be increased interest . . . in responsibly-sourced ingredients and environmentally sustainable products, and we believe we are well-positioned to benefit from the resulting changes in consumer preferences due to our social impact and sustainability efforts,” in addition to related risk factor disclosure on pages 18 and 19. • Your response indicates you have taken actions to mitigate the risk of increasing alternative energy costs, and that the cost of these actions to date has not been material. Provide support for your determination of materiality, including quantitative information for each of the periods covered by your Form 10-K and expected to be incurred in future periods.

Given the nature of the Company's products it is difficult to identify how and whether a specific consumer purchasing decision is impacted by the Company's sustainability initiatives. As a result, the Company's strategy has been to routinely obtain insights from consumers, as well as through actions taken by, and insights from, our retailers, in the ordinary course of business to evaluate whether there are any consumer preferences that are reasonably likely to have a material impact on our business.

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To that end, we periodically conduct consumer insight surveys, including elements related to sustainability characteristics and consumers' overall views on the Company’s sustainability initiatives. Insights from some of our consumers indicate a preference for companies that are perceived to be environmentally responsible, which may include sustainability of packaging, sourcing of products, and formulations. However, this preference has not been identified as a primary driver for our consumers' purchasing decisions globally, based on the results of these surveys and related analysis and actions taken by our retailers. That said, we believe that the actions we are taking in these areas as highlighted in our SIS report position us to meet the preferences of our consumers. We recognize consumer priorities and preferences may change in the future and we will continue to monitor and analyze shopping behaviors.

While we and our competitors are focusing on sustainability initiatives, our consumer preference trends globally do not indicate a significant change to our competitive landscape as a result of these matters. However, consistent with above, we believe the actions we are taking in these areas position us to remain competitive as consumer priorities and preferences evolve.

As part of the Company’s quarterly disclosure process, the Company assesses the business trends driving its operating results. The Company internally discusses observed trends and potential trends to consider for disclosure. We do not specifically track and evaluate the quantitative impact that climate-related changes in demand and competition have on our consolidated results; however, through our disclosure process, we have not identified any trends that indicate climate-related changes in demand and competition have materially affected, or are reasonably likely to materially affect our business.

1.We note your response to prior comment 2. Please further address the following:

• Clarify whether your SIS goals and targets (e.g., carbon neutrality across Scope 1 and Scope 2 emissions and sourcing 100% renewable energy for your direct operations) are related to changes in demand and competition for products that result in lower greenhouse gas emissions, are not derived from carbon-based sources, and/or are produced using alternative energy sources. In this regard, we note disclosure of page 12 of your Form 10-K that, “There continues to be increased interest . . . in responsibly-sourced ingredients and environmentally sustainable products, and we believe we are well-positioned to benefit from the resulting changes in consumer preferences due to our social impact and sustainability efforts,” in addition to related risk factor disclosure on pages 18 and 19.

Company Response:

At The Estée Lauder Companies, we see sustainability as important to not only managing our business for the long term, but also helping to improve the resilience of our broader global communities. First and foremost, our SIS goals and targets have been established as a result of our desire to become a more sustainable company by improving our impact on the environment. Integrating sustainability throughout our business is a strategic imperative and we continue to embed sustainability throughout our operations. Throughout the Form 10-K, we include reference to certain areas of our business where sustainability is integrated into our overall strategy, including through our research and development, manufacturing, warehousing and raw materials, highlighting our commitments to develop more environmentally responsible products and reduce our impact on the environment.

Additionally, as discussed in our first response above, we acknowledge there are insights from some of our consumers that indicate a preference for companies that are perceived to be environmentally responsible, which may include sustainability of packaging, sourcing of products, and formulations. However, this preference has not been identified as a primary driver for our consumers' purchasing decisions globally and does not indicate a significant change to our competitive landscape. Consumer demand and competition is not the primary purpose and focus of our SIS goals and targets. That said, as discussed above our current goals and targets include elements that are related to sustainability areas where we believe consumers have an increased interest and where we see competitors focusing, and position us for the continuing evolution of consumer preferences regarding sustainability.

1.We note your response to prior comment 2. Please further address the following:

• Your response indicates you have taken actions to mitigate the risk of increasing alternative energy costs, and that the cost of these actions to date has not been material. Provide support for your determination of materiality, including quantitative information for each of the periods covered by your Form 10-K and expected to be incurred in future periods.

Company Response:

The project costs to date for our actions taken with regard to alternative energy, excluding the carbon offsets and renewable energy credits included in our prior response letter, include capital expenditures for solar technology and other energy efficiency upgrades primarily to our supply chain facilities, as well as certain operating expenditures associated with our Virtual Power Purchase agreement and feasibility assessments. In fiscal 2023, 2022, and 2021, the capital expenditures were approximately $2 million, $2 million and $4 million, respectively, and the operating expenses were less than $0.5 million in each fiscal year. At this time, the amounts expected to be incurred in the future do not materially differ from the amounts incurred to date.

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We note your response to prior comment 3. Please further address the following: • Provide us with quantitative information regarding weather-related damages to your property or operations for each of the periods covered by your Form 10-K, rather than the example of uninsured costs resulting from Hurricane Sandy in 2012.

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• Your response that the Company has not experienced a material impact in instances where your direct material suppliers experienced temporary business impact due to weather-related impacts appears conclusory in nature. Tell us about the impact you have experienced in these instances and how you evaluated materiality, including by providing the quantification requested by our prior comment. • Your response does not specifically address water-related issues, although these appear to be highlighted in your SIS Report, which states that “Access to high-quality water is essential to our business.” Tell us how you considered disclosing the importance of water to the Company and describing water-related risks and uncertainties, including your assessment of materiality on your business and operations.

With regards to the impact of weather-related damages to our property and operations, damages are communicated through our normal reporting processes, including through the frequent interactions of our various functions and teams.

No weather-related damages have been noted by the business in the last three fiscal years, aside from tornado damage to one of our manufacturing facilities in Pennsylvania in fiscal 2021. This tornado damage resulted in total damages of approximately $1.5 million, of which $250,000 was not covered by insurance.

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Although there could be incremental de minimis damages that are not being specifically tracked and reported as weather-related, given our understanding of the impacts of weather-related events on our business noted above, including a lack of severe weather events occurring that have directly impacted our property and operations overall, we have concluded that there are no material costs being incurred by the business related to weather-related damages to our property and operations.

2.We note your response to prior comment 3. Please further address the following:

• Your response that the Company has not experienced a material impact in instances where your direct material suppliers experienced temporary business impact due to weather-related impacts appears conclusory in nature. Tell us about the impact you have experienced in these instances and how you evaluated materiality, including by providing the quantification requested by our prior comment.

Company Response:

Although we have had instances where our direct material suppliers experienced temporary business impacts due to weather-related impacts, any incremental costs to the Company have not been tracked as we have not experienced significant disruptions to our business. This is due to the business continuity plans in place both at the Company and at our suppliers, including dual-sourcing, safety-stock, and multiple facilities, which have mitigated the impacts. If there were any significant impacts, including to our costs or disruptions in sales, these would be identified and communicated through our normal reporting processes, which include the frequent interactions of our various functions and teams. The following are the events of which we are aware that have occurred at our suppliers in the periods covered by our fiscal 2023 Form 10-K:

•A folding carton supplier in the United States was hit by a tornado, and a third of their warehouse roof was torn off, impacting the lead time needed for a temporary period.

•Oil-related ingredient suppliers surrounding the Gulf of Mexico have been impacted by hurricanes resulting in short-term closure of facilities.

•Excessive heat in Germany caused the Rhine River water levels to drop to levels that did not allow for ship traffic resulting in short-term delays from suppliers.

While these events did have a short-term impact on our suppliers, including to our supplier lead time and supply of packaging and raw materials, as a result of our business continuity planning, including safety-stock and dual sourcing of materials, any financial impact was mitigated.

2.We note your response to prior comment 3. Please further address the following:

• Your response does not specifically address water-related issues, although these appear to be highlighted in your SIS Report, which states that “Access to high-quality water is essential to our business.” Tell us how you considered disclosing the importance of water to the Company and describing water-related risks and uncertainties, including your assessment of materiality on your business and operations.

Company Response:

As highlighted in our SIS Report, access to water is important to our business. As a result of this, we have proactively assessed the risks associated with water (including water stress, water quality, drought and flooding) to ensure we are monitoring and addressing these risks in order to limit potential impacts that could come to fruition in the future.

In fiscal 2022, we executed an enterprise-wide multi-phased water risk assessment. Water related business risks were assessed for direct operations including manufacturing, research and development, distribution, warehouse, administrative offices, and global retail locations. We engaged an external consulting firm which used data from the WRI Aqueduct Water Risk Atlas Tool to prioritize sites for further analysis based on a risk rating that included weightings applied to overall water risk (which is an aggregate of physical quantity, quality and regulatory & reputational risk categories), baseline water stress and projected water stress indicators. Prioritized sites were further analyzed to take into account local conditions and assigned a separate risk score. From the two risk scores (WRI Aqueduct and the consultant scores) a composite score was calculated for the prioritized sites. Medium to high water risk was assigned to facilities that had a composite score greater than 3.0. Based on this assessment, we identified two of our directly operated manufacturing sites (Melville, NY and Oevel, Belgium) as having a medium to high water risk.

Our manufacturing facility in Melville, New York, United States, is located in a region that is considered high water stressed and based on the water risk assessment at high risk for water quality and it is expected that this region will become increasingly stressed in the future due to climate change. At Melville, we manufacture skin care products, including creams and lotions, and fill fragrances, and all of these processes require water.

Our manufacturing facility in Oevel, Belgium, is located in a region that is considered extremely high water stressed and at high risk for water quality. It is expected that this region will remain stressed in the future due to climate change. At Oevel, we manufacture skin care products, including creams and lotions, and makeup products, and all of these processes require water.

Currently, there are various actions the Company has taken and plans to take to mitigate this impact. For Melville, this includes reducing our withdrawal of groundwater and municipal supplied water at this facility, including through the implementation of a well water bypass reduction system, improvements in water metering and maintenance equipment, which began in fiscal 2022, with an initial cost of $0.4 million. For Oevel, this includes recycling water on-site which began in fiscal 2014, with an initial cost of $0.3 million, and an additional $0.1 million in annual operating costs. A conceptual design of a new wastewater treatment plant for Oevel with an improved recycling ambition was completed in fiscal 2023, and we are continuing with the design of this system in fiscal 2024. If the Melville or Oevel campuses were without water or had to significantly reduce water usage for two weeks, we estimate that we could potentially lose sales of approximately $53 million, or less than 0.5% of consolidated net sales using fiscal 2023 net sales as the baseline, for Melville, or $80 million, or approximately 0.5% of consolidated net sales using fiscal 2023 net sales as the baseline, for Oevel, and these amounts do not assume any mitigating actions we could take including a shift of production to other facilities and deployment of inventory from other facilities. Based on this estimation and timeframe of this risk (potential risk would not be expected to come to fruition until more than six years in the future for Melville and four to six years in the future for Oevel), and the actions the Company has taken and plans to take to mitigate this risk, we determined that it did not present a material risk to our business.

In addition to our direct operations, we have also identified a supplier within our value chain that has a longer-term water risk (potential risk would not be expected to come to fruition until more than six years in the future). We work with a supplier located in the Seine River basin, France, which creates finished samples. The possible financial impact of this risk relates to loss of net sales associated with the products manufactured at our supplier's France site. We estimate that inability to sell the products tied to these samples would have a potential impact of $13 million per year, or less than 0.1% of consolidated net sales using fiscal 2023 net sales as the baseline, based on historic trends. Therefore, this is the maximum financial impact we would experience if the supplier ceased to operate. However, this supplier is a multi-national supplier with the ability to manufacture products from sites in other locations mitigating the risk identified here.

While we have considered whether disclosure of the importance of water on our business is needed, based on our overall assessment of risks including as noted above, we have not identified a material risk to our business, and do not anticipate any significant impacts to our business that need to be addressed through material capital expenditures or operating expenses in the near-term. We will continue to monitor this risk and evaluate the adequacy of our disclosures in this area in future filings.

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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.

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