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United States securities and exchange commission logo
March 30, 2022
Melissa Schaeffer
Senior Vice President and Chief Financial Officer
AIR PRODUCTS & CHEMICALS INC /DE/
1940 Air Products Boulevard
Allentown, Pennsylvania 18106
Re: AIR PRODUCTS &
CHEMICALS INC /DE/
Form 10-K for the
Year Ended September 30, 2021
Form 10-Q for the
Period Ended December 31, 2021
File No. 001-04534
Dear Ms. Schaeffer :
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 Period Ended December 31, 2021
Note 6. Equity Affiliates
Equity Affiliate Investment in Jazan Integrated Gasification and Power
Company (JIGPC), page
13
1. In regards to your
initial investment of $1.6 billion in the Jazan Integrated Gasification
and Power Company,
which was made primarily in the form of shareholder loans and
represents a 55%
interest in the joint venture, please address the following:
Given your
disclosures indicate that the investment was primarily made in the form
of loans, please
help us understand how you determined that the equity method would
be appropriate
pursuant to ASC 323-10-15-3;
Please provide us
with a summary of your significant rights and obligations under the
joint venture
agreement and correspondingly explain how you determined you have
significant
influence under ASC 323; and
Please tell us how
much of the $1.6 billion was in the form of loans. If the entire
Melissa Schaeffer
AIR PRODUCTS & CHEMICALS INC /DE/
March 30, 2022
Page 2
$1.6 billion was not in the form of loans, please tell us the
remaining components of
the investment and corresponding amounts.
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 Nudrat Salik at (202) 551-3692 or Al Pavot at (202)
551-3728 with any
questions.
FirstName LastNameMelissa Schaeffer Sincerely,
Comapany NameAIR PRODUCTS & CHEMICALS INC /DE/
Division of Corporation Finance
March 30, 2022 Page 2 Office of Life Sciences
FirstName LastName