SEC Company Response from KIMBERLY CLARK CORP (KMB) (CIK 0000055785) (KMB) — May 1, 2026
KIMBERLY CLARK CORP (KMB) (CIK 0000055785)
Date: May 1, 2026 · CIK: 0000055785 · Accession: 0001104659-26-054171
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-00225
Referenced dates: April 27, 2026
Letter
Via EDGAR Division of Corporation Finance Office of Manufacturing United States Securities and Exchange Commission Re: Kimberly-Clark Corporation Form 10-K for the Year Ended December 31, 2025 Filed February 12, 2026 File No. 001-00225
Dear Ms. Yang and Mr. Blume:
The following is in response to the comments of the staff (the "Staff") of the Division of Corporation Finance of the Securities and Exchange Commission contained in the comment letter dated April 27, 2026 pertaining to the Form 10-K for the fiscal year ended December 31, 2025 of Kimberly-Clark Corporation (the "Company") filed on February 12, 2026 (the "Form 10-K"). The Staff's comments are repeated below (in bold-italics type) with the Company's response following (in regular type).
Form 10-K for the Year Ended December 31, 2025 Filed February 12, 2026
Notes to the Consolidated Financial Statements
Note 1. Accounting Policies
Revenue Recognition, page 49
1. 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. 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.
Ms. Stephany Yang and Mr. Andrew Blume Page 2
United States Securities and Exchange Commission
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.
2. Pursuant to ASC 280-10-50-41(b), please disclose entity-wide information concerning long-lived assets by geographic area in future filings.
The Company acknowledges the Staff's comment and advises 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. 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
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.
***********************************
Ms. Stephany Yang and Mr. Andrew Blume Page 3
United States Securities and Exchange Commission
If you have any questions pertaining to the foregoing, please feel free to contact me at (972) 281-1474.
Sincerely,
/s/ Nelson Urdaneta
Show Raw Text
CORRESP
1
filename1.htm
May 1, 2026
Via EDGAR
Ms. Stephany Yang and Mr. Andrew Blume
Division of Corporation Finance
Office of Manufacturing
United States Securities and Exchange Commission
100 F. Street, NE
Washington, D.C. 20549
Re:
Kimberly-Clark Corporation
Form 10-K for the Year Ended December 31, 2025
Filed February 12, 2026
File No. 001-00225
Dear Ms. Yang and Mr. Blume:
The following is in response to the comments of the staff (the "Staff")
of the Division of Corporation Finance of the Securities and Exchange Commission contained in the comment letter dated April 27, 2026
pertaining to the Form 10-K for the fiscal year ended December 31, 2025 of Kimberly-Clark Corporation (the "Company") filed
on February 12, 2026 (the "Form 10-K"). The Staff's comments are repeated below (in bold-italics type) with the Company's
response following (in regular type).
Form 10-K for the Year Ended December 31, 2025 Filed February
12, 2026
Notes to the Consolidated Financial Statements
Note 1. Accounting Policies
Revenue Recognition, page 49
1. 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. 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.
Ms. Stephany Yang and Mr. Andrew Blume
Page 2
United States Securities and Exchange Commission
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.
2. Pursuant to ASC 280-10-50-41(b), please disclose entity-wide information concerning long-lived assets by geographic area in
future filings.
The Company acknowledges the Staff's comment and advises
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. 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.
***********************************
Ms. Stephany Yang and Mr. Andrew Blume
Page 3
United States Securities and Exchange Commission
If you have any questions pertaining to the foregoing, please feel
free to contact me at (972) 281-1474.
Sincerely,
/s/ Nelson Urdaneta
Nelson Urdaneta
Senior Vice President and Chief Financial Officer