Philip Morris International (PM) CORRESPCorrespondence with SEC

Set forth below is the heading and text of each comment from your September 21, 2022 letter followed by our response.

As discussed in our response to comment number two in the Initial Comment Letter, when preparing the Form 10-K, we leveraged our enterprise risk management practices and personnel from across our organization to (i) evaluate potential material risks, including transition risks related to climate change, (ii) assess whether such risks are material to our business, and (iii) confirm the accuracy and completeness of our disclosures in light of the applicable disclosure requirements and guidance. In our October 2021 Low-Carbon Transition Plan ("LCTP"), we indicated that the primary climate change related transition risks identified through these processes were (i) the impact of evolving international, national, and local environmental and climate-related laws and regulations in the countries where we operate and (ii) risks related to market changes, such as shifts in supply and demand for certain commodities, products, and services that could lead to increased costs of sourcing and increased costs for suppliers. These and the other climate change related transition risks mentioned by the Staff, and how we considered providing disclosure about these transition risks, are discussed individually below.

First, we face the possible adoption and implementation of carbon-pricing mechanisms in countries where we operate, such as the European Union emissions trading scheme, which could lead to an increase in our operating costs in the future if not sufficiently mitigated. We manage and mitigate this risk both through our overall corporate decarbonization targets, which aim to achieve carbon neutrality in our operations (scope 1+2) by 2025 and net zero emissions across our entire value chain (scope 1+2+3) by 2040, and by incorporating carbon emissions impact analysis in the planning for our internal projects, which allows us to better understand the potential impact of external carbon pricing on profitability and prioritize investments that accelerate emissions reduction. Based on this risk management approach, and the enterprise risk management practices outlined above and in the Initial Comment Letter, we concluded that this particular climate change related transition risk did not give rise to a material risk to our business or results that required inclusion in the Risk Factors section of our Form 10-K.

In addition to the climate change related transition risks discussed above, we analyzed other climate change related transition risks and determined that these risks did not constitute primary climate related risks to our business. For example, the use of climate risk metrics by credit rating agencies and general trend of investors decarbonizing their investment portfolio create investment market and credit risks. As discussed above and in the Initial Response Letter, we have voluntarily set ambitious goals and targets for decarbonizing our direct operations and our value chain. We believe that this strategy will significantly mitigate these risks to PMI and, for the periods reported in the Form 10-K, these risks did not materially impact our business or profitability.

Additionally, we face mid- and long-term transition risks related to technology, specifically technology improvements, as existing equipment becomes non-compliant with evolving energy regulations, too expensive to run due to the higher fuel costs, or inconsistent with our decarbonization goals and targets. In order to achieve our decarbonization strategy, we will need to invest in new technology, implement technological advancements, and avoid investing in technologies whose emissions characteristics are inconsistent with our goals and targets. These investments are an important component of our decarbonization strategy, as explained in more detail in the LCTP. However, as discussed in our response to comment number five in the Initial Comment Letter, our capital expenditures for climate-related projects have been, and are expected to continue to be, immaterial to PMI. We believe we can mitigate this risk through our planned investments without materially adversely impacting our business or profitability. For these reasons, we have not identified technology-related risks as a primary current or future climate change related transition risk.

Relying on the risk identification processes described above and in the Initial Response Letter, in preparing the Form 10-K we determined that, except as described above, transition risks related to climate change, are not among our material risks. We will, however, continue to evaluate and assess these and other risks to our business in connection with future filings.

We respectfully inform the Staff that while we are unable to predict with specificity the nature or the extent of the potential for indirect weather-related impacts that have or may affect our customers, due to the diversified nature of our business, the

As discussed in more detail in our response to comment number eight in the Initial Comment Letter, PMI���s primary costs for compliance with environmental regulations are related to our manufacturing facilities. For each of fiscal 2019 and fiscal 2020, the annual total global environmental compliance cost for our facilities manufacturing cigarettes and heated tobacco units was less than 0.05% of our consolidated cost of sales and marketing, administration, and research costs.

We will continue to monitor our climate-change compliance costs and will update disclosures accordingly in future filings if such costs have a material impact on our business, financial condition or results of operations.