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October 21, 2022
Timothy R. Kraus
Senior Vice President and Chief Financial Officer
Dana Incorporated
3939 Technology Drive
Maumee, Ohio 43537
Re:Dana Incorporated
Form 10-K for Fiscal Year Ended December 31, 2021
Response Dated October 13, 2022
File No. 001-01063
Dear Timothy R. Kraus:
            We have reviewed your October 13, 2022 response to our comment letter 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.  Unless we note otherwise, our references to prior comments are to comments in our
September 29, 2022 letter.
Response Dated October 13, 2022
Risk Factors, page 7
1.We note your response to prior comment one and reissue it as your response does not
appear to have addressed transition risks related to climate change.  Please tell us how you
considered providing disclosure addressing the transition risks related to climate change
identified in our previously issued comments, including with regard to your assessment of
their effect on your business, financial condition, and results of operations.

 FirstName LastNameTimothy R. Kraus
 Comapany NameDana Incorporated
 October 21, 2022 Page 2
 FirstName LastName
Timothy R. Kraus
Dana Incorporated
October 21, 2022
Page 2
Management's Discussion and Analysis of Financial Condition and Results of Operations, page
15
2.We note your response to prior comment two quantifies expenditures for climate-related
projects for 2021.  Please provide quantification for each of the other periods covered by
your Form 10-K, or affirmatively state if there were no such expenditures.  Additionally
tell us if amounts are expected to increase in future periods.
3.We note your response, yet reissue prior comment three as it does not appear that each of
the items identified in our original comment (i.e., comment five of our letter dated August
26, 2022) is addressed in your response.  Please provide us with your analysis of the
indirect consequences of climate-related regulations or business trends for each of the
items noted in our prior comment.  Include information explaining how the disclosed risks
related to such consequences specifically address developments regarding climate change
or tell us how you concluded on the materiality of the items for which disclosure was not
deemed necessary.
            Please contact Erin Donahue at 202-551-6063 or Jennifer Angelini at 202-551-3047 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing