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April 20, 2011

FILED VIA EDGAR; ORIGINAL SENT VIA UPS

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, DC 20549

    Attention:

    John Reynolds

Assistant Director

         Re:

    Avery Dennison Corporation

Form 10-K for Fiscal Year Ended January 1, 2011

Filed February 28, 2011

File No. 1-7685

Ladies and Gentlemen:

In connection with the comments contained in the April 7, 2011 letter (the “Comment Letter”) from
the staff of the Commission (the “Staff”) to Dean A. Scarborough, Chairman, President and Chief
Executive Officer of Avery Dennison Corporation (the “Company”), the Company’s responses to the
Staff’s comments are presented below.

For your convenience, we have set forth each of the Staff’s comments contained in the Comment
Letter, followed by our response.

Form 10-K for the Year Ended January 1, 2011

Management’s Discussion and Analysis

Analysis of Results of Operations

Provision (Benefit from) Income Taxes, page 18

    1.

    We note from your disclosure in Note 11 that your effective tax rate reflects a benefit from
a local statutory write down of certain investments in Europe and the releases and accruals of
certain tax reserves. Please provide us with and confirm in future Exchange Act filings you
will revise to include a detailed discussion of each of these items and a discussion of
whether you expect them to continue to impact your income tax accounts.

Securities and Exchange Commission

Division of Corporate Finance

Attn: John Reynolds, Assistant Director

April 20, 2011

Page 2

Thank you for your comment. We will revise the tax note to our consolidated financial statements,
as well as the corresponding disclosure in our Management’s Discussion and Analysis (“MD&A”), in
future filings to include the following disclosure regarding the 2010 tax rate:

    The 2010 effective tax rate reflects $45.5 million of benefit from net operating
losses resulting from a local statutory write down of certain investments in Europe
due to a decline in their value. The decline in value established a net operating
loss asset subject to recapture. As a result of a legal entity restructuring, the
liability for the recapture was eliminated, therefore causing the Company to
recognize a discrete tax benefit in the fourth quarter. The Company does not expect
events of this nature to occur frequently since declines in the value of
subsidiaries are uncommon. The 2010 effective tax rate also reflects $17.7 million
of net benefit from normally-occurring releases and accruals of certain tax
reserves, which were in part due to reductions in the Company’s tax positions for
prior years due to settlements with taxing jurisdictions and lapses of applicable
statutory periods.

    2.

    In connection with the comment above, please provide us with and confirm in future
Exchange Act filings you will revise to provide a detailed discussion of the discrete tax
planning event that is expected to lower cash tax payments over the coming years that was
referred to in your 2010 4th quarter earnings call.

We appreciate your comment. Please refer to our response to Staff comment #1 above for
additional disclosure we will include in future filings regarding the event referred to in our 2010
4th quarter earnings call. In addition, in future filings we will include the following
statement in our existing disclosure regarding net operating losses to address the expectation of
lower future cash tax payments:

    Net operating losses, including the net operating losses which resulted from the
local statutory write down of certain investments in Europe referenced above, may
offset future taxable income, thereby lowering cash tax payments over the coming
years.

Consolidated Financial Statements

Notes to Consolidated Financial Statements

Note 8 — Contingencies

Environmental Matters, page 52

Securities and Exchange Commission

Division of Corporate Finance

Attn: John Reynolds, Assistant Director

April 20, 2011

Page 3

    3.

    We note you have accrued environmental remediation liabilities for certain sites where it is
probable that a loss will be incurred and the cost can be reasonably estimated. Please tell
us, and confirm in future filings you will disclose, the amount or range of reasonably
possible environmental remediation losses to which you are exposed. If such range cannot be
estimated or is not material to the financial statements, state so. Refer to FASB ASC
450-20-50-3.

Thank you for your comment. We will revise the contingencies note to our consolidated financial
statements, as well as the corresponding disclosure in our MD&A, in future filings to include the
following disclosure regarding environmental matters:

    The Company has accrued liabilities for sites where it is probable that a loss will
be incurred and the cost or amount of loss can be reasonably estimated. Because of
the uncertainties associated with environmental assessment and remediation
activities, future expense to remediate these sites could be higher than the
liabilities accrued by the Company; however, the Company is unable to reasonably
estimate a range of potential expenses. If information becomes available that
allows the Company to reasonably estimate the range of potential expenses or an
amount higher or lower than what it has accrued, the Company will adjust its
environmental liabilities accordingly. In addition, the Company could identify
additional sites for cleanup in the future; until such sites are identified, the
range of expense for remediation cannot be determined.

Part IV

Item 15. Exhibits

    4.

    We note that exhibits 10.18.2, 10.31.2, 10.35, and 10.36 to the Form 10-K do not have some or
all of the schedules, attachments, or exhibits as listed in the exhibit itself. We also note
that you have not filed all of the schedules, annexes, and/or exhibits to Exhibit 10.1 to the
Form 10-Q filed on August 7, 2008. In your next periodic report, please file these exhibits
in their entirety as required by Item 601(b)(10) of Regulation S-K or advise.

As requested, we will file exhibits 10.18.2, 10.31.2, 10.35 and 10.36 to our 2010 Form 10-K, as
well as exhibit 10.1 to our Form 10-Q filed on August 7, 2008, in their entirety with our Form 10-Q
for the first quarter of 2011.

Securities and Exchange Commission

Division of Corporate Finance

Attn: John Reynolds, Assistant Director

April 20, 2011

Page 4

In addition, the Company acknowledges that:

    •

    the Company is responsible for the adequacy and accuracy of the disclosure in the
filing;

    •

    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.

We appreciate the opportunity to respond to your comments. If you have any questions or require
additional information regarding our responses, please do not hesitate to contact Scott Hodgkins of
Latham & Watkins at (213) 891-8739 or the undersigned at (626) 304-2064.

    Sincerely,

    /s/ Lori J. Bondar

    Lori J. Bondar

    Vice President, Controller and

Chief Accounting Officer

    cc:

    Dean A. Scarborough

Mitchell R. Butier

Susan C. Miller

Scott Hodgkins, Latham & Watkins LLP