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 February 26, 2026

Marc Vandiepenbeeck
Chief Financial Officer
Johnson Controls International plc
One Albert Quay
Cork, Ireland T12 X8N6

 Re: Johnson Controls International plc
 Form 10-K for the Fiscal Year Ended September 30, 2025
 File No. 001-13836
Dear Marc Vandiepenbeeck:

 We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments.

 Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.

Form 10-K for the Fiscal Year Ended September 30, 2025
Management's Discussion and Analysis of Financial Condition and Result of
Operations, page
31

1. We note your disclosure on page 6 indicates that management uses backlog
and orders as
 tools to monitor the performance of the business and provide management
with a deeper
 level of insight into the progress of specific strategic and growth
initiatives. Please revise
 to include a qualitative and quantitative discussion of such metrics for
each period
 presented to enhance a readers understanding of your business similar to
slides 9 and 10
 of your Fiscal Q4 2025 Earnings Conference Call investor presentation
which addresses
 changes by segment and solution. Refer to SEC Release No. 33-10751.
Segment Analysis, page 35

2. We note your disclosure of Segment EBITA appears to be an additional
segment
 measure of profit. Please revise to identify this additional measure of
segment profit or
 loss as non-GAAP and provide the disclosures required by Item
10(e)(1)(i) of Regulation
 S-K. Similar concerns apply to your disclosures in your earnings
releases furnished on
 Form 8-K.
 February 26, 2026
Page 2

Consolidated Financial Statements
Note 18. Segment Information
Geographic Areas, page 100

3. We note approximately 44% of your revenue was from foreign
jurisdictions. Please tell
 us whether revenue from any individual foreign country is material and
if so, how you
 considered the guidance in ASC 280-10-50-41(a).
 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.

 Please contact Megan Masterson at 202-551-3407 or Christine Dietz at
202-551-3408
with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Technology
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