SecProbe.io

Mail Stop 3561
May 17, 2017

Mr. Nik Jhangiani
Coca -Cola European Partners PLC
Bakers Road, Uxbridge
UB8 1EZ
United Kingdom

Re: Coca -Cola European Partners PLC
 Form 20-F for the Year Ended December 31, 2016
Filed April 12, 2017
File No. 1 -37791

Dear Mr. Jhangiani :

We have limited our review  of your filing  to the financial statements and related
disclosures 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 busine ss days by providing the requested
information or advis e us as soon as possible when you will respond.  If you do not be lieve 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.

Liquidity and Capital Management, page 19

1. You state adjusted EBITDA is calculated as EBITDA, before adding back certain non -
recurring expense items.  Please tell us how you determined that each item added back
was non -recurring or revise your disclosure to remove the non -recurring characterization.
Refer to Item 10 (e)(1)(i i)(B) of Regulation S -K.

2. It appears you are using adjusted EBITDA and the resultant net debt to adjusted EBITDA
measure to manage your liquidity and capital resources.  If so, please reconcile adjusted
EBITDA to cash flows from operating activiti es and provide equally prominent
disclosure of your cash flows from operating, investing and financing activities.  If not,
please explain your basis for believing these measures are performance measures, and not
liquidity ones, and reconcile adjusted EBIT DA to net income, rather than operating
profit.  Refer to Item 10(e)(1)(i)(A) of Regulation S -K and Questions 102.06 and 103.02
of the Compliance and Disclosure Interpretations regarding Non -GAAP Measures, as
revised in May 2016.

Mr. Nik Jhangiani
Coca -Cola European Partners PLC
May 17, 2017
Page 2

 Financial Statements
Note 3. Segment Information, page 106

3. Please provide us with your analysis of how you determined you have one operating
segment.  In your response, please address the following:

 Tell us the title and describe  the role of the CODM and  each of the individuals  who
report to the CODM.   If the general managers of your various regional business units
discussed on pages 169 to 170 do not report to the CODM, please also describe their
role and how they fit into your organizational structure.

 Explain the various for ms of discrete financial information regularly reviewed by
your CODM that is at a disaggregated or lower level than your consolidated results.
Please explain the nature of any profitability information that is reviewed by your
CODM at a level lower than yo ur consolidated results and explain how often this
information is provided to and reviewed by your CODM.

 If lower level or disaggregated information is not regularly reviewed by the CODM,
tell us who is responsible for allocating resources and assessing p erformance below
the consolidated level and explain how that works.

 Tell us the nature of the resource allocation decisions made by the CODM and what
components of the business they choose between in their allocation of resources.

 Explain how budgets are  prepared, who approves the budget at each step of the
process, the level of detail discussed at each step and the level at which the CODM
makes changes to the budget.

 Describe the level of detail communicated to the CODM when actual results differ
from b udgets and who is involved in the meetings with the CODM to discuss budget -
to-actual variances.

 Describe the basis for determining the compensation for each individual  that reports
to the CODM.

Also, in the event you determine that you have more than one operating segment pursuant
to the guidance in IFRS 8, but that these operating segments meet the aggregation criteria
outlined in paragraph 12 of IFRS 8, please explain in further detail the basis for your
conclusion that your operating segments a re economically similar.

4. Please disclose the revenues derived from each of your principal products for each period
presented.  Refer to paragraph 32 of IFRS 8.

Mr. Nik Jhangiani
Coca -Cola European Partners PLC
May 17, 2017
Page 3

 Note 4. Earnings Per Share , page 106
5. Please disclose by type of potentially dilutive security,  such as stock options and
restricted shares, the number of additional shares that could potentially dilute basic
earnings per share in the future, but were not included in the calculation of diluted
earnings per share because they were antidilutive for th e periods presented.  Refer to
paragraph 70(c) of IAS 33.

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.

You may contact Linda Cvrkel at (202)  551-3813 or me at ( 202) 551-3769  with any
questions.

Sincerely,

 /s/ Rufus Decker

Rufus Decker
Accounting Branch Chief
Office of Beverages, Apparel and
Mining