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Celulosa Arauco y Constitución S.A.

July 12, 2023

VIA EDGAR TRANSMISSION

Office of Manufacturing

Attn Heather Clark and Melissa Gilmore

Division of Corporation Finance

U.S. Securities & Exchange Commission

100 F Street, NE

Washington, DC

    Re:
    Arauco & Constitution Pulp Inc.

    Form 20-F for Fiscal Year Ended December 31, 2022

    Form 6-K furnished March 29, 2023

    File No. 33-99720

Dear Ms. Clark and Ms. Gilmore,

This letter responds to comments of the staff (the “Staff”)
of the Securities and Exchange Commission (the “Commission”) set forth in a letter dated June 6, 2023, regarding the
above-referenced Annual Report on Form 20-F for the fiscal year ended December 31, 2022 (the “Annual Report”) of Celulosa
Arauco y Constitución S.A. (Arauco & Constitution Pulp Inc.) (“Arauco”), as well as the above-referenced
Press Release on Form 6-K furnished March 29, 2023.

Concurrently with this letter, we have filed Amendment
No. 1 to the Annual Report (the “Form 20-F/A”) via EDGAR, which reflects the changes made in response to the Comment
Letter. The financial and other information included in the 20-F remains the same as that which was filed on April 19, 2023 in the Annual
Report. A marked copy of Amendment No. 1, which shows changes from the Annual Report, is being submitted supplementally for the convenience
of the Staff.

We have reproduced the Staff’s comments below
in bold and provided our response immediately below each comment.

Office of Manufacturing

Attn: Heather Clark and Melissa Gilmore

July 12, 2023, p. 2

Form 20-F for the Year Ended December 31, 2022

Financial Statements

Notes to Consolidated Financial Statements as of December 31, 2022
and 2021

Note 16. Interest in Joint Arrangements, page F-64

 1. We note from page F-65 that the income of Celulosa y Energia Punta Pereira S.A. is material to your
net income for the year ended December 31, 2022. In this regard, please clarify your ownership percentage of this entity and your consideration
of providing financial statements under Instruction 1 to Item 8 of Form 20-F and Article 3-09 of Regulation S-X.

The Company respectfully advises the Staff
that Arauco’s ownership percentage over Celulosa y Energía Punta Pereira S.A as of December 31, 2022 corresponds to 50%.

As described in Note 16 of the Consolidated
Financial Statements; the Company classified its investment in Celulosa y Energía Punta Pereira S.A as a joint operation based
on its contractual rights and obligations and recognized the assets, liabilities, income and expenses associated with its ownership interest
as specified in the contractual arrangement pursuant to IFRS 11, Joint Arrangements.

According to the Federal Register Document
No. 94-984 and section 6540.4.c of the "Division of Corporation Finance - Financial Reporting Manual", separate financial statements
of a joint venture being proportionally consolidated are not required.

Based on the foregoing, the Company respectively
informs the Staff that separate financial statements of Celulosa y Energía Punta Pereira S.A are not required to be provided in
Form 20-F under Rule 3-09 of Regulation S-X since the Company accounts for such joint arrangement as a joint operation and recognizes
the assets, liabilities, income and expenses associated with its ownership interest in the Company’s consolidated financial statements.

Exhibits 12.1, 12.2 and 13.1, page 1

 2. Please amend to provide signed certifications in your Form 20-F.

Arauco acknowledges receipt
of the Staff’s comments regarding Exhibits 12.1, 12.2 and 13.1 (the “Exhibits”), and has filed the 20-F/A to include
the Exhibits. As described above, the 20-F/A has been concurrently filed along with this letter in response to the Staff’s comments.

Form 6-K furnished March 29, 2023

Press Release 4Q 2022, page 12

 3. We note your calculation of the non-IFRS measure you identify as "free cash flow" appears
to differ from the standard calculation of this measure (i.e., cash flows from operations less capital expenditures). In order to avoid
potential confusion, please revise the title of your non-IFRS measure in future filings to “adjusted free cash flow” or something
similar. Refer to Question 102.07 of the Division of Corporation Finance’s Compliance & Disclosure Interpretations on Non-GAAP
Financial Measures.

Arauco acknowledges receipt of the Staff’s comment and
will revise the title assigned to this measure to the extent it differs from the standard calculations of this matter in future press
releases furnished on Form 6-K.

*	          *	          *

Office of Manufacturing

Attn: Heather Clark and Melissa Gilmore

July 12, 2023, p. 3

We acknowledge that we are responsible for the adequacy
and accuracy of the disclosure in the 2022 Form 20-F; staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the 2022 Form 20-F; and that we may not assert comments of the Commission staff
as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

We are grateful for your assistance in this matter.
If you have any questions or require any additional information with respect to the above, please do not hesitate to contact Arauco or
Duane McLaughlin (+1-212-225-2106) of our U.S. counsel Cleary Gottlieb Steen & Hamilton LLP.

    Sincerely,

    By:
    /s/ Gianfranco Truffello

    Gianfranco Truffello

    Chief Financial Officer

    Celulosa Arauco y Constitución S.A. (Registrant)

cc.:       Duane McLaughlin

Cleary Gottlieb Steen & Hamilton LLP