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August 11, 2023
Jean-Pierre Sbraire
Chief Financial Officer
TotalEnergies SE
2, place Jean Millier
La Defense 6
92400 Courbevoie
France
Re:TotalEnergies SE
Form 20-F for Fiscal Year Ended December 31, 2022
Response dated July 13, 2023
File No. 001-10888
Dear Jean-Pierre Sbraire:
            We have reviewed your July 13, 2023 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
June 16, 2023 letter.
Form 20-F for fiscal year ended December 31, 2022
Item 5. Operating and Financial Review and Prospects, page 2
1.Please address the following regarding certain of the information and sample disclosures
you provided in response to prior comment 1:

•Provide us with an example of the reconciliation tables you will present for Adjusted
net operating income, Adjusted net income, Capital employed used in Return on
Average Capital Employed (ROACE) and Net debt used in Gearing.

•Clarify for us why you consider Adjusted EBITDA to be a valuable tool to measure

 FirstName LastNameJean-Pierre Sbraire
 Comapany NameTotalEnergies SE
 August 11, 2023 Page 2
 FirstName LastName
Jean-Pierre Sbraire
TotalEnergies SE
August 11, 2023
Page 2
and compare your profitability with utility companies.  In this regard, we note you
characterize your business as a global multi-energy company in Section 1.1.1 of your
Universal Registration Document 2022.

•Tell us your consideration of the following as non-GAAP measures and provide the
disclosures required by Item 10(e) of Regulation S-K as necessary:oPayout, net investments, page 2
oOrganic investments, Net acquisitions, and Net investments, page 4
oVariable cost margin – Refining Europe, VCM, page 4
5.3 Business segment reporting, page 9
2.We have considered your response to prior comment 4 and specifically, your position that
presentation of multiple financial measures at the segment level are not non-GAAP
financial measures.  Pursuant to the guidance in Question 104.01 and 104.03 of the Non-
GAAP Financial Measures Compliance & Disclosure Interpretations, multiple measures
of segment profit or loss not expressly permitted by IFRS 8 would be deemed as non-
GAAP measures.  Therefore, it does not appear that presentation of multiple financial
measures at the segment level as presented comply with Item 10(e) of Regulation S-K and
should be revised as necessary.  Refer to comment 3 below for further information.
Financial Statements
Notes to the Consolidated Financial Statements
Note 3 Business segment information, page F-23
3.We have considered your response to prior comment 6 and specifically, your position
that paragraphs 23 and 26 of IFRS 8 do not preclude disclosure of additional performance
measures.  However we note that paragraph 23 of IFRS 8 requires disclosure of a single
measure of profit or loss for each reportable segment.  Additional measures of a segment’s
profit or loss may be presented within Item 5 of the Form 20-F provided that the
disclosures related to any additional measures comply with Item 10(e) of Regulation S-K.
Further we note paragraph 26 of IFRS 8 does not contemplate presentation of information
similar to that of a full income statement for segments.  Presentation of non-GAAP
‘adjusted full income statements’ in the financial statement or in the accompanying notes
are prohibited under Item10(e)(1)(ii)(C) of Regulation S-K.  Accordingly, please revise
this Note 3 to disclose the single measure of segment profit or loss as determined in
accordance with paragraph 26 of IFRS 8 and provide the reconciliation as required by
paragraph 28(b) of IFRS 8 or provide us with the specific accounting literature that
supports your position.

 FirstName LastNameJean-Pierre Sbraire
 Comapany NameTotalEnergies SE
 August 11, 2023 Page 3
 FirstName LastName
Jean-Pierre Sbraire
TotalEnergies SE
August 11, 2023
Page 3
             You may contact Jennifer O'Brien, Staff Accountant, at 202-551-3721 or Raj Rajan,
Staff Accountant, at 202-551-3388 with any questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation