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CORRESP
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CORRESP

 June 19, 2017

 Melissa
Raminpour

 Branch Chief

 United States Securities and
Exchange Commission

 Division of Corporation Finance

 100 F.
Street, N.E.

 Washington, D.C. 20549

Re:
Autoliv, Inc.

 Form 10-K for the Fiscal Year
Ended December 31, 2016

 Filed February 23, 2017

File No. 001-12933

Dear Ms. Raminpour:

 We hereby respond to
the comments of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”), as set forth in the Staff’s letter of comments dated May 30, 2017 (the “Comment Letter”), to the above
referenced filing of Autoliv, Inc. (the “Company”). The Company has filed, via EDGAR, this letter (tagged Correspondence).

 The
Company has the following responses to the Staff’s comments in the Comment Letter. For your convenience, we have reproduced in italics below each comment from the Comment Letter with the response following.

Form 10-K for the quarter ended December 31, 2016

General

1.
In Exhibit 13 to your Form 10-K, you list the automakers to which you sold products in 2016. We are aware of publicly available information indicating that some of those
automakers sell vehicles in Sudan and/or Syria, countries which are designated as state sponsors of terrorism by the U.S. Department of State and are subject to U.S. economic sanctions and export controls. You do not include disclosure about any
contacts with Sudan or Syria. Please describe to us the nature and extent of any past, current and anticipated contacts with Sudan and Syria, whether through subsidiaries, joint ventures, customers or other direct or indirect arrangements. You
should describe any products, technology and services you have provided into Sudan and Syria, directly or indirectly, and any agreements, arrangements or other contacts you have had with the governments of Sudan and Syria or entities they
control.

 RESPONSE:

The Company and its subsidiaries and joint ventures do not have, and do not anticipate having, any contacts with Sudan or Syria and do not
directly provide any products, technology or services into Sudan or Syria. Additionally, the Company and its subsidiaries and joint ventures do not have, and do not anticipate having, any agreements, arrangements or contacts with the governments of
Sudan and Syria or entities under the control of such governments. The Company does not have any subsidiaries, facilities, employees, joint venture interests, investments or other assets in Sudan and Syria.

 United States Securities and Exchange Commission

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 The Company sells its products directly to original equipment manufacturers
(“OEMs”) for incorporation into new motor vehicles. It does not directly sell its products to any Sudanese or Syrian vehicle manufacturers. Many OEMs are foreign companies that manufacture vehicles outside the United States and the Company
has foreign subsidiaries that sell its products to such OEMs. The Company has no reason to believe its products sold to OEMs for use in their foreign manufacturing activities are incorporated in finished vehicles that are sold into Sudan or
Syria in violation of any laws. The Company has no control over where such OEMs may deliver such vehicles. The Company also has in place corporate policies and procedures to ensure its own compliance with U.S. export and sanctions regulations.

Form 10-K for the quarter ended December 31, 2016

General

2.
Please discuss the materiality of any contacts with Sudan and Syria you describe in response to the comment above, and whether the contacts constitute a material investment risk for your security holders. You should
address materiality in quantitative terms, including the approximate dollar amounts of any revenues, assets and liabilities associated with Sudan and Syria for the last three fiscal years and the subsequent interim period. Also, address materiality
in terms of qualitative factors that a reasonable investor would deem important in making an investment decision, including the potential impact of corporate activities upon a company’s reputation and share value. Various state and municipal
governments, universities and other investors have proposed or adopted divestment or similar initiatives regarding investment in companies that do business with U.S.-designated state sponsors of terrorism. You should address the potential impact of
the investor sentiment evidenced by such actions directed toward companies that have operations associated with Sudan and Syria.

RESPONSE:

 No disclosure was deemed
necessary in the Company’s Annual Report on Form 10-K for the year ended December 31, 2016 (the “Form 10-K”) because, as described in Response 1
above, the Company has and had no contacts with Syria or Sudan. If any sales occurred in any of 2014, 2015 or 2016 by OEMs into Syria and Sudan of foreign manufactured motor vehicles incorporating Company products manufactured by its foreign
subsidiaries, such sales would have been immaterial.

 The Company does not believe any sales by OEMs into Sudan and Syria of foreign
manufactured vehicles incorporating the Company’s products would constitute a material investment risk for the Company’s stockholders. The Company has in place the policies and controls described in Response 1 above to ensure its own
compliance with U.S. export and sanctions regulations.

 The Company has not received any inquiries from investors or analysts regarding
whether the Company has contacts with Sudan or Syria. The Company has also not received any indication from investors that the Company is in a category of companies where investors are considering divestment initiatives related to investments in
companies that do business with U.S.-designated state sponsors of terrorism. Moreover, we believe that the Company’s lack of contact with Sudan and Syria and the de minimis amount,

 United States Securities and Exchange Commission

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if any, of Company products made by foreign subsidiaries that are incorporated into foreign-made vehicles delivered into those countries by OEMs is unlikely to harm investor sentiment regarding
the Company’s securities.

 Form 10-K for the quarter ended December 31, 2016

General

3.
On page 4, you state that you manufacture night vision systems. Night vision devices and technology are included in the U.S. Department of Commerce’s Commerce Control List. Please tell us whether, to the best of
your knowledge, understanding and belief, any of the products or technology you have provided or intend to provide, directly or indirectly, into Sudan and Syria are controlled items included in the Commerce Control List. If so, tell us whether any
such items have military uses, and describe such possible uses of which are you aware.

 RESPONSE:

The Company manufactures certain camera systems which incorporate focal plane arrays to allow for enhanced vision and imaging in darkness, and
are specially designed for installation into civilian passenger land vehicles. The cameras are not designed for military use and the Company is unaware of any such use. The cameras are configured solely to assist a driver in the safe operation of a
vehicle; they are only operable when installed in certain civilian passenger land vehicles, and they incorporate an active mechanism that forces the cameras not to function when removed from the vehicle for which they are intended. Based on these
and other characteristics, the cameras are classifiable in ECCN 6A993 on the Commerce Control List (“CCL”).

 The Company sells
its products to OEMs for incorporation into civilian passenger land vehicles. The Company has no reason to believe that the camera systems described above are being incorporated into vehicles that are sold to Sudan or Syria. The Company utilizes
provisions in its contracts with customers for these types of camera systems to ensure compliance with U.S. export and sanctions regulations. In the case of the cameras classifiable in ECCN 6A993, the Company notifies all customers of the export
classification to facilitate compliance with U.S. export regulations. The Company also has in place corporate policies and procedures to ensure its own compliance with U.S. export and sanctions regulations. Additionally, with respect to the
Company’s cameras classifiable in ECCN 6A993, the Company follows specific policies and procedures to help ensure that the products are not used other than for their intended purpose in civilian passenger land vehicles.

 United States Securities and Exchange Commission

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 Exhibit 13

Management’s Discussion and Analysis

Year Ended December 31, 2016 Versus 2015

4.
We note from your disclosure in Note 19 to the financial statements, that you have identified two operating segments, Passive Safety and Electronics. We further note that although your MD&A discussion in your
Quarterly Reports on Form 10-Q includes a discussion of your operating results by segment, your MD&A section in your Form 10-K does not. In this regard, please
revise your MD&A in your Form 10-K to discuss and analyze your results of operations for each of these operating segments.

RESPONSE:

 The Company acknowledges the
Staff’s comment and respectfully advises that, although not included in the MD&A, the Company does not believe that this resulted in material information not being available to stockholders because it otherwise provided to its stockholders
the disclosure related to segments referenced in the Staff’s comment. The Company included a discussion related to the two operating segments in other parts of the Company’s Annual Report to Stockholders for the fiscal year ended
December 31, 2016 (the “Annual Report”) filed as Exhibit 13 to the Form 10-K. The Company included information regarding net sales and operating margin of its Passive Safety Segment on page 8 of
the Annual Report and of its Electronics Segment on page 9 of the Annual Report. The Company will include such disclosure in the MD&A in its future filings on Form 10-K. For ease of reference, the
information regarding operating segments from the Annual Report is included below:

 Passive Safety (page 8)

Consolidated segment sales grew by close to 4% to $7,919 million compared to $7,621 million in the full year 2015. Excluding negative
currency translation effects of more than $161 million, the organic sales growth was 6%. The organic sales growth was mainly due to higher sales in Europe, China, Japan, North America and India.

The improvement in operating margin is primarily because costs relating to antitrust matters and capacity alignments (particularly European)
were higher in 2015 than in 2016.

 Sales of airbag products (including steering wheels) were favorably impacted by higher sales of
inflatable curtains in Japan and Europe, and steering wheels, especially in Europe.

 Sales of seatbelt products were particularly strong in
Europe and China. The global trend towards more advanced and higher value-added seatbelt systems continued globally.

 Electronics
(page 9)

 Consolidated sales increased by close to 40% compared to the full year 2015. Excluding acquisition effects from ANBS and
MACOM of $426 million and negative currency translation effects of more than $11 million, the organic sales growth was more than 13%.

The lower operating margin was mainly a result of costs related to the formation of ANBS and higher costs for R,D&E, net, partially offset
by higher organic sales.

 United States Securities and Exchange Commission

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 Growth in organic sales for passive safety electronics products (mainly airbag control
modules and remote sensing units) was due to growth across most regions, particularly in China.

 The strong increase in sales of active
safety products (automotive radars, night vision systems, cameras with driver assist systems and positioning systems) resulted from growth particularly for radar products in North America and camera and radar products in Europe.

Sales of brake control systems were in line with our expectations from the start of operations of ANBS in the beginning of the second quarter
of 2016.

 Additionally, in its earnings release for the fourth quarter and full year 2016, furnished as an exhibit to the Company’s Form 8-K furnished to the Commission on February 2, 2017 (the “Earnings Release”), the Company included quarterly and yearly information related to sales, income and headcount per segment in the
“Segment Information” section on pages 6 and 10 in the Earnings Release. For ease of reference, the information from the Earnings Release is included below:

Quarterly Information (page 6)

Passive Safety

 (Dollars in millions)

Q4 2016

Q4 2015

Change

Organic
change*

 Segment sales

$
2,035.3

$
2,068.3

(1.6
)%

0.7%

 Segment operating income

$
228.5

$
264.5

(13.6
)%

 Segment operating margin

11.2%

12.8%

(1.6
)pp

 Consolidated segment sales decreased by 1.6% to $2,035 million compared to $2,068 million in the same
quarter of 2015. Excluding negative currency translation effects of $47 million, the organic sales growth* was almost 1%. Strong organic growth in China was offset by a decline in North America in the quarter. The operating margin decline was
primarily a result of higher investments in R,D&E, net, as well as other costs to support future growth.

 Electronics

 (Dollars in millions)

Q4 2016

Q4 2015

Change

Organic
change*

 Segment sales

$
584.1

$
463.2

26.1
%

3.4%

 Segment operating income

$
29.8

$
32.3

(7.7
)%

 Segment operating margin

5.1%

7.0%

(1.9
)pp

 Consolidated segment sales were significantly higher compared to the same quarter of 2015, primarily due to the
inclusion of Autoliv-Nissin Brake Systems (ANBS). The organic sales growth* was more than 3%, driven by strong organic sales growth in Passive Safety Electronics coming primarily from China and South Korea. The lower operating margin was mainly a
result of higher costs to support future growth as well as costs relating to the formation of ANBS.

 United States Securities and Exchange Commission

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 Yearly Information (page 10)

Passive Safety

 (Dollars in millions)

Full Year 2016

Full Year 2015

Change

Organic
change*

 Segment sales

$
7,918.8

$
7,621.2

3.9
%

6.0%

 Segment operating income

$
817.7

$
669.2

22.2
%

 Segment operating margin

10.3%

8.8%

1.5
pp

 Consolidated segment sales grew by close to 4% to $7,919 million compared to $7,621 million in the
full year 2015. Excluding negative currency translation effects of more than $161 million, the organic sales growth* was 6%. The organic sales growth was mainly due to higher sales in Europe, China, Japan, North America and India. The
improvement in operating margin is primarily because costs relating to antitrust matters (including settlements) and capacity alignments (particularly the European capacity alignment program) were higher in 2015 than in 2016.

Electronics

 (Dollars in millions)

Full Year 2016

Full Year 2015

Change

Organic
change*

 Segment sales

$
2,215.6

$
1,588.7

39.5
%

13.3%

 Segment operating income

$
61.5

$
64.5

(4.7
)%

 Segment operating margin

2.8%

4.1%

(1.3
)pp

 Consolidated sales increased by close to 40% compared to the full year 2015. Excluding acquisition effects from
ANBS and MACOM of $426 million and negative currency translation effects of more than $11 million, the organic sales growth* was more than 13%. The lower operating margin was mainly a result of costs relating to the formation of ANBS and
higher costs for R, D&E, net, partially offset by higher organic sales.

 The Company has revised its approach with respect to its
presentation of its operating results by segment in its most recent Form 10-Q for the first quarter of 2017, filed with the Commission on April 28, 2017. In future filings on Form 10-K, the Company will include in its MD&A discussion, with respect to its operating segments for the year, disclosure similar to the disclosures provided i