SecProbe.io

March 31, 2020
Michael Casamento
Chief Financial Officer
Amcor PLC
83 Tower Road North
Warmley, Bristol BS30 8XP
United Kingdom
Re:Amcor PLC
Form 10-K for the Fiscal Year Ended June 30, 2019
Form 10-Q for the Fiscal Quarter Ended December 31, 2019
Form 8-K furnished February 11, 2020
File No. 001-38932
Dear Mr. Casamento:
            We have reviewed your filings 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.
Form 10-K for the Fiscal Year Ended June 30, 2019
Financial Statements
Consolidated Statement of Cash Flows, page 43
1.We note from your disclosure in Note 4 that the Bemis acquisition in 2019 was a
significant stock only acquisition.  Please revise the statement of cash flows to disclose all
noncash investing and financing activities as required by ASC 230-10-50-3.
2.We note that you have included an adjustment to reconcile net income to net cash
provided by operating activities of $77.9 million titled “other, net.”  Please identify for us
the nature of this adjustment.

 FirstName LastNameMichael Casamento
 Comapany NameAmcor PLC
 March 31, 2020 Page 2
 FirstName LastNameMichael Casamento
Amcor PLC
March 31, 2020
Page 2
Notes to Consolidated Financial Statements
Note 10 - Fair Value Measurements, page 60
3.We note from your disclosures that during 2019 and 2018 you had several impairments
such as the $31.1 million impairment for a technology intangible in 2019 and a $36.5
million impairment to an equity method investment in 2019.  Please revise to include
disclosures related to assets and liabilities measured at fair value on a nonrecurring basis
as required by ASC 820-10-50-2.
Form 10-Q for the Fiscal Quarter Ended December 31, 2019
Financial Statements
Notes to Condensed Consolidated Financial Statements
Note 14 – Segments, page 29
4.We note from your disclosure on page 29 that you aggregate your five Flexibles operating
segments into one reportable segment.  It appears from your disclosure on page 31 that
sales from North America were over 50% of total sales for the six month ended December
31, 2019.   Explain to us how you evaluated the aggregation criteria in ASC 280-10-50-11
in determining you have only one Flexibles reportable segment.  In doing so, explain in
sufficient detail how you determined your operating segments have similar economic
characteristics.
Management's Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations – Three Months Ended December 31, 2019
Consolidated Results of Operations, page 37
5.We note that you present net sales and Adjusted EBIT “on a comparative basis” for the
comparable period in fiscal 2018.  Please note that due to different basis of accounting, we
do not consider it appropriate to combine results from the accounting acquiree and
acquiror without the appropriate Regulation S-X, Article 11 adjustments.  Please revise to
remove this combined presentation from all relevant discussion in your MD&A.
Alternatively, you may present and discuss changes with the prior year period on a pro
forma basis, consistent with Article 11 of Regulation S-X.
General
6.We note that it appears from your statements of cash flow, that during the six months
ended December 31, 2019, the loss on transition to hyperinflationary accounting for
Argentine subsidiaries is material to your income statement. Please revise the notes to the
financial statements to disclose your accounting policy for highly inflationary economies.
Also, please consider the disclosures outlined in ASC 830-20-50.

 FirstName LastNameMichael Casamento
 Comapany NameAmcor PLC
 March 31, 2020 Page 3
 FirstName LastName
Michael Casamento
Amcor PLC
March 31, 2020
Page 3
Form 8-K furnished February 11, 2020
Exhibit 99.1
Presentation of Prior Year Information, page 2
7.We note from pages 2 and 7 that your earnings release includes certain combined amounts
considered supplemental unaudited combined financial information which were not
prepared in accordance with Article 11 of Regulation S-X.  Therefore, it is unclear why
you believe that the supplemental unaudited combined financial information current
discussion is appropriate and that providing a supplemental discussion of pro forma
financial information would not be more meaningful to an investor, considering that your
current presentation excludes pro forma adjustments calculated under Article 11 of
Regulation S-X.  Considering your disclosures in the 8-K that certain adjustments were
made to the combined data, please tell us how the supplemental unaudited combined
financial information compares to amounts calculated in accordance with Article 11 of
Regulation S-X.  We may have further comment upon receipt of your response.
            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 Heather Clark at 202-551-3624 or Claire Erlanger at 202-551-3301 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing