Form 10-K for the Year Ended December 31, 2025
Your revenue recognition disclosure appears to refer to terminology and recognition principles in ASC 605. Please revise future filings to ensure your disclosures appropriately address the guidance in ASC 606.
The Company acknowledges the Staff’s comment and advises the Staff that the Company will revise its disclosure in future filings, commencing with the Form 10-K for the fiscal year ending December
31, 2026, to better address the guidance in ASC 606. By way of illustration, the Company provides the below example as if this disclosure had been included in the Form 10-K.
Revenue Recognition
Our revenue contracts typically consist of a single performance obligation to sell our products to customers.Read in the reply ↗Rest of the answer
Revenue is recognized at a single point in time when control over the products transfers to the customer, which occurs upon shipment or delivery of the products depending on the contractual shipping terms.
Revenue is reported net of trade and consumer promotions, returns, discounts, and rebates and excludes taxes collected by the Company on behalf of governmental authorities. We account for shipping and handling as fulfillment activities with related revenues recorded within Net sales and costs recorded within Cost of products sold.
Trade and consumer promotions, mainly comprised of customer pricing allowances, merchandising funds and consumer coupons, as well as discounts, rebates and sales returns, are accounted for as variable consideration and are recorded as a reduction in revenue in the same period as the related sale is recognized. Promotion and rebate accruals are based on the estimated sales volumes for the incentive period and also consider the estimated number of consumer coupons that will be redeemed. We review and adjust these estimates at least quarterly based on actuals and other information. The related liability is recognized within Accrued expenses and other current liabilities on the Consolidated Balance Sheets.
First report after the company's reply of 2026-05-01: 10-Q filed 2026-08-04 ↗, against the 10-Q filed 2025-10-30 ↗.
Note 1, Accounting Policies: 7 paragraphs changed; the 3 closest in words to the question are below.
In December 2023, 2025, the FASB issued ASU 2023-09, Income Taxes No. 2025-10, Government Grants (Topic 740). The new 832) to establish guidance is intended to enhance on the transparency recognition, measurement and decision usefulness presentation of annual income tax disclosures. government grants received by business entities. The amendments in this ASU are effective for fiscal years beginning after December 15, 2024. Early 2028, and interim periods within those fiscal years, with early adoption is permitted, and the permitted. The amendments should can be applied on a modified prospective basis, a modified retrospective basis with or a retrospective application permitted. As basis. We are currently evaluating the guidance requires only additional disclosure, there will be no effects impact of this standard update on our financial position, results of operations or cash flows. Consolidated Financial Statements and related disclosures.
On June 5, 2025, we announced that the Company will form a joint venture with Suzano S.A. ("Suzano") and Suzano International Holding B.V., a wholly-owned subsidiary of Suzano ("Buyer"), comprised of substantially all the operations of the Company's former International Family Care and Professional ("IFP") segment (the "IFP Business"). To facilitate this transaction, we entered into an Equity and Asset Purchase Agreement (the "Purchase Agreement") with Buyer, pursuant to which we will, among other things, effectuate a reorganization through the transfer of certain assets, liabilities and equity interests of the IFP Business to Kimberly-Clark IFP NewCo B.V., an indirect wholly-owned subsidiary of the Company (the "Joint Venture"). At the time of closing, which is expected to take place in mid-2026 and will only take place following the satisfaction of consultation requirements and customary closing conditions, including obtaining required regulatory approvals, Buyer will acquire a 51 % interest in the Joint Venture for a purchase price of approximately $ 1.7 billion, subject to certain closing adjustments set forth in the Purchase Agreement, and we will retain a 49 % equity interest (the "IFP Transaction"). On July 1, 2026, subsequent to the quarter ended June 30, 2026, all consultation requirements and customary closing conditions set forth in the Purchase Agreement were satisfied and the IFP Transaction was completed. See Note 11 for further details.
As of July 1, 2018, we adopted highly inflationary accounting for our subsidiaries in Argentina (“K-C Argentina”). The effect of changes in exchange rates on peso-denominated monetary assets and liabilities has been reflected in earnings in Other (income) and expense, net. As of September June 30, 2025, 2026, K-C Argentina had an immaterial net peso monetary position. Net sales of K-C Argentina were approximately 1 % of our consolidated net sales for the three and nine six months ended September June 30, 2025 2026 and 2024. 2025.
Paragraphs where only numbers, dates or period words changed are not shown. Cut words struck through, new words highlighted and underlined.
Pursuant to ASC 280-10-50-41(b), please disclose entity-wide information concerning long-lived assets by geographic area in future filings.
the Staff that the Company’s long-lived assets consist of Property, plant, and equipment, net (“PP&E”) and that the Company disclosed the total amount of our PP&E globally ($6,775 million) and the total amount of our PP&E for the United States, our country of domicile ($4.9 billion), in Note 17 – Supplementary Data on page 83 of the Form 10-K.Read in the reply ↗Rest of the answer
Historically, we have determined that our long-lived assets for any individual country outside of the United States are not material.
The Company advises the Staff that it will revise its disclosure in future filings, commencing with the Form 10-K for the fiscal year ending December 31, 2026, to provide this information more explicitly in tabular format. By way of illustration, the Company provides the below example as if this disclosure had been included in the Form
10-K.
December 31
2025
2024
Long-lived Assets by Geography
United States
$ 4,851
$ 4,361
International
1,924
1,923
Total Long-lived Assets(a)
$ 6,775
$ 6,284
(a) Long-lived assets consist of Property, plant and equipment, net.
First report after the company's reply of 2026-05-01: 10-Q filed 2026-08-04 ↗, against the 10-Q filed 2025-10-30 ↗.
The part of the filing the question names could not be found in both reports. Read them on sec.gov.
Also in this review: closing letter, 2026-05-05