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 Oatly Group AB
 Ångfärjekajen 8
 211 19 Malmö
 Sweden VIA EDGAR
 May 13, 2025 U.S. Securities & Exchange
Commission Division of Corporation Finance Office of
Manufacturing 100 F Street, NE Washington, D.C. 20549
 Attn: Bradley Ecker and Evan Ewing

 Re:
 Oatly Group AB
 Registration Statement on Form F-3
 Filed March 25, 2025, as amended
 File No. 333-286101
 Ladies and Gentlemen: Pursuant to Rule 461 of the General Rules
and Regulations of the Securities and Exchange Commission promulgated under the Securities Act of 1933, as amended, Oatly Group AB hereby respectfully requests that the effective date of the above-captioned Registration Statement on Form F-3 (the “Registration Statement”) be accelerated to, and that the Registration Statement be declared effective at, 4:30 p.m. Washington, D.C. time on May 15, 2025, or as soon as
practicable thereafter. If you have any questions, please contact the Company’s counsel, Laura Katherine Mann, at laurakatherine.mann@whitecase.com,
or by telephone at 713-496-9695, and please notify her when this request for acceleration has been granted.

 Sincerely,

 /s/ Jean-Christophe Flatin

 Jean-Christophe Flatin Chief Executive
Officer

 cc:
 Matthew Merritt, Oatly Group AB
 Timothy Sjövall, Oatly Group AB
 Laura Katherine Mann, White & Case LLP
 Shoan Panahi, White & Case Advokat AB

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 Oatly Group AB
 Ångfärjekajen 8
 211 19 Malmö Sweden
 VIA EDGAR April 30, 2025
 U.S. Securities & Exchange Commission Division of
Corporation Finance Office of Manufacturing 100 F Street,
NE Washington, D.C. 20549 Attn: Bradley Ecker and Evan
Ewing

 Re:
 Oatly Group AB
 Registration Statement on Form F-3
 Filed March 25, 2025
 File No. 333-286101
 Dear Messrs. Ecker and Ewing: Oatly Group AB
(the “ Company ,” “ we ,” “ our ” or “ us ”) hereby transmits the Company’s response to the comment letter received from the staff (the “ Staff ”) of the U.S. Securities
and Exchange Commission (the “ Commission ”), on April 7, 2025, regarding our Registration Statement on Form F-3 filed with the Commission on March 25, 2025.
 For the Staff’s convenience, we have repeated below the Staff’s comments in bold, and have followed each comment with the
Company’s response. Disclosure changes made in response to the Staff’s comments have been made in the Amended Registration Statement on Form F-3 (the
“ F-3/A ”), which is being filed with the Commission contemporaneously with the submission of this letter.
 Cover Page

 1.
 Please revise your cover page to disclose that the American Depositary Shares you are registering for resale
are issuable upon the conversion of the Convertible Senior PIK Notes. Refer to Item 501 of Regulation S-K.
 Company’s Response: The Company respectfully acknowledges the Staff’s comment. In response, the Company has revised the cover page to
disclose that the American Depositary Shares being registered for resale are issuable upon the conversion of the Convertible Senior PIK Notes.
 General

 2.
 Please revise the registration statement to disclose the material terms of the Convertible Senior PIK Notes
or provide a cross reference to the relevant disclosure in your annual report on Form 20-F filed March 13, 2025.
 Company’s Response: The Company respectfully acknowledges the Staff’s comment. In response, the Company has provided a cross
reference to Item 5.B “ Liquidity and Capital Resources—Convertible Notes ” and Item 3.D “ Risk Factors—Risks Related to our Indebtedness and Outstanding Convertible Notes ” of our annual report on Form 20-F filed March 13, 2025 on page 7 of the F-3/A.
 1

 3.
 Please file the Subscription Agreement as an exhibit to the registration statement or tell us why you are
not required to do so. Company’s Response: The Company respectfully acknowledges the Staff’s comment. In
response, the Company has filed the Subscription Agreement as Exhibit 4.4 to the F-3/A. We thank
the Staff for its review of the foregoing and the F-3/A. If you have further comments, please feel free to contact the Company’s counsel, Laura Katherine Mann, at laurakatherine.mann@whitecase.com, or by
telephone at (713) 496-9695.

 Sincerely,

 /s/ Jean-Christophe Flatin

 Jean-Christophe Flatin Chief Executive
Officer

 cc:
 Matthew Merritt, Oatly Group AB
 Timothy Sjövall, Oatly Group AB
 Laura Katherine Mann, White & Case LLP
 Shoan Panahi, White & Case Advokat AB
 2

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 April 7, 2025

Jean-Christophe Flatin
Chief Executive Officer
Oatly Group AB
 ngf rjekajen 8
211 19 Malm
Sweden

 Re: Oatly Group AB
 Registration Statement on Form F-3
 Filed on March 25, 2025
 File No. 333-286101
Dear Jean-Christophe Flatin:

 We have conducted a limited review of your registration statement and
have the
following comment(s).

 Please respond to this letter by amending your registration statement
and providing
the requested information. If you do not believe a comment applies to your
facts and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

 After reviewing any amendment to your registration statement and the
information
you provide in response to this letter, we may have additional comments.

Form F-3 filed March 25, 2025
Cover Page

1. Please revise your cover page to disclose that the American Depositary
Shares you are
 registering for resale are issuable upon the conversion of the
Convertible Senior PIK
 Notes. Refer to Item 501 of Regulation S-K.
General

2. Please revise the registration statement to disclose the material terms
of
 the Convertible Senior PIK Notes or provide a cross reference to the
relevant
 disclosure in your annual report on Form 20-F filed March 13, 2025.
3. Please file the Subscription Agreement as an exhibit to the registration
statement or
 tell us why you are not required to do so.
 April 7, 2025
Page 2

 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.

 Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

 Please contact Bradley Ecker at 202-551-4985 or Evan Ewing at
202-551-5920 with
any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Manufacturing
</TEXT>
</DOCUMENT>

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 Oatly Group AB

Jagaregatan 4

 211 19 Malmö

 Sweden

 May 17, 2021

VIA EDGAR AND E-MAIL

United States Securities and Exchange Commission

 Division of
Corporation Finance

 100 F Street, N.E.

 Washington, D.C.
20549-6010

 Attention:      Mandy Hooker

John Cash

 Geoff Kruczek

Asia Timmons-Pierce

Re:
 Oatly Group AB

Registration Statement on Form F-1 (File
No. 333-255344)

 Ladies and Gentlemen:

In accordance with Rule 461 of Regulation C of the General Rules and Regulations under the Securities Act of 1933, as amended, we hereby
request acceleration of the effective date of the Registration Statement on Form F-1 (File No. 333-255344) (the “Registration Statement”) of
Oatly Group AB (the “Company”). We respectfully request that the Registration Statement become effective as of 4:00 p.m., Eastern Time, on May 19, 2021, or as soon as practicable thereafter. Once the Registration
Statement has been declared effective, please orally confirm that event with our counsel, Latham & Watkins LLP, by calling Marc Jaffe at (212) 906-1281.

Thank you for your assistance in this matter.

[signature page follows]

Very truly yours,

Oatly Group AB

By:

 /s/ Toni Petersson

Name: Toni Petersson

Title: Chief Executive Officer

cc:
 (via email)

Christian Hanke, Oatly Group AB

Marc D. Jaffe, Latham & Watkins LLP

Ian D. Schuman, Latham & Watkins LLP

Stelios G. Saffos, Latham & Watkins LLP

Alexander D. Lynch, Weil, Gotshal & Manges LLP

Barbra J. Broudy, Weil, Gotshal & Manges LLP

CORRESP
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 1271 Avenue of the Americas

New York, New York 10020-1401

Tel: +1.212.906.1200 Fax: +1.212.751.4864

www.lw.com

FIRM / AFFILIATE OFFICES

Beijing

Moscow

Boston

Munich

Brussels

New York

Century City

Orange County

Chicago

Paris

Dubai

Riyadh

 May 17, 2021

Düsseldorf

San Diego

Frankfurt

San Francisco

Hamburg

Seoul

Hong Kong

Shanghai

Houston

Silicon Valley

London

Singapore

Los Angeles

Tokyo

Madrid

Washington, D.C.

Milan

 VIA EDGAR AND HAND DELIVERY

United States Securities and Exchange Commission

 Division of
Corporation Finance

 100 F Street, N.E.

 Washington, D.C.
20549-6010

 Attention:

 Mandy Hooker

 John Cash

 Geoff Kruczek

 Asia Timmons-Pierce

       Re:

Oatly Group AB

Registration Statement on Form F-1

Filed on April 19, 2021

CIK No. 0001843586

 Ladies and Gentlemen:

On behalf of Oatly Group AB, previously referred to as Havre Global AB (the “Company”), we are hereby filing Amendment
No. 2 (“Amendment No. 2”) to the Registration Statement on Form F-1 (Registration No. 333-255344)
filed with the Commission on April 19, 2021, as amended on May 11, 2021 (“Amendment No. 1”). The Company previously submitted a Draft Registration Statement on Form F-1 on a confidential basis pursuant to Title I, Section 106 under the Jumpstart Our Business Startups Act with the Securities and Exchange Commission (the “Commission”) on
February 12, 2021, as amended on March 25, 2021. Amendment No. 2 has been revised to reflect the Company’s responses to the comment letter to Amendment No. 1 received on May 14, 2021 from the staff of the Commission
(the “Staff”).

 For ease of review, we have set forth below each of the numbered comments of your letter in bold
type followed by the Company’s responses thereto.

 Dilution, page 67

1.
 Please provide a tabular presentation of a pro forma dilution calculation utilizing the pro forma net
tangible book value referenced in the second paragraph on page 67.

 Response: The Company
respectfully acknowledges the Staff’s comment and has revised page 67 of Amendment No. 2.

 May 17, 2021

 Page
 2

 General

2.
 We note your disclosure that in connection with the Concurrent Private Placements you will receive repayment
of any outstanding loans owed to you by some of the warrant holders. Please disclose the amount the loans owed by the warrant holders. If appropriate, please update your Related Party Transactions section.

Response: The Company respectfully acknowledges the Staff’s comment and has revised pages 15 and 18 of Amendment No. 2. The
Company advises the Staff that the warrant holders with outstanding loans are company employees, not any executive officers or directors of the Company.

* * *

 We hope the foregoing
answers are responsive to your comments. Please do not hesitate to contact me by telephone at (212) 906-1281 with any questions or comments regarding this correspondence.

Very truly yours,

 /s/ Marc D. Jaffe

 Marc D. Jaffe

 of LATHAM & WATKINS
LLP

cc:
 (via email)

Toni Petersson, Oatly Group AB

Christian Hanke, Oatly Group AB

Ian D. Schuman, Latham & Watkins LLP

Stelios G. Saffos, Latham & Watkins LLP

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 May 17, 2021

VIA EDGAR AND E-MAIL

United States Securities and Exchange Commission

 Division of
Corporation Finance

 100 F Street, N.E.

 Washington, D.C.
20549-6010

Attention:
 Mandy Hooker

John Cash

 Geoff Kruczek

Asia Timmons-Pierce

Re:
 Oatly Group AB

Registration Statement on Form F-1 (File
No. 333-255344)

 Ladies and Gentlemen:

In connection with the above-captioned Registration Statement and offering, we, the representatives of the underwriters (the
“Representatives”), wish to advise you that, pursuant to Rule 460 of the General Rules and Regulations under the Securities Act of 1933, as amended (the “Act”), the underwriters have distributed
approximately 1,082 copies of the Preliminary Prospectus dated May 11, 2021 through the date hereof, to underwriters, dealers, institutions and others.

We, the undersigned Representatives, have been informed by the participating underwriters that they will comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended, in connection with the proposed offering.

 In accordance
with Rule 461 of the Act, we hereby join in the request of the registrant that the effectiveness of the above-captioned Registration Statement, as amended, be accelerated to 4:00 p.m. Eastern Time, on May 19, 2021 or as soon thereafter as
practicable.

 [signature page follows]

Very truly yours,

MORGAN STANLEY & CO. LLC

J.P. MORGAN SECURITIES LLC

CREDIT SUISSE SECURITIES (USA) LLC

For themselves and as representatives of the syndicate of underwriters for the offering

By MORGAN STANLEY & CO. LLC

By:

 /s/ Josh Kamboj

Vice President

By J.P. MORGAN SECURITIES LLC

By:

 /s/ Jaclyn M. Berkley

Executive Director

By CREDIT SUISSE SECURITIES (USA) LLC

By:

 /s/ Sophie van Kleef

Director

 [SIGNATURE PAGE TO ACCELERATION REQUEST OF THE UNDERWRITERS]

United States securities and exchange commission logo
May 14, 2021
Christian Hanke
Chief Financial Officer
Oatly Group AB
Stora Varvsgatan 6a
211 19 Malmö
Sweden
Re:Oatly Group AB
Amendment No. 1 to Registration Statement on Form F-1
Filed May 11, 2021
File No. 333-255344
Dear Mr. Hanke:
            We have reviewed your amended registration statement 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 this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
Form F-1/A filed May 11, 2021
Dilution, page 67
1.Please provide a tabular presentation of a pro forma dilution calculation utilizing the pro
forma net tangible book value referenced in the second paragraph on page 67.
General
2.We note your disclosure that in connection with the Concurrent Private Placements you
will receive repayment of any outstanding loans owed to you by some of the warrant
holders.  Please disclose the amount the loans owed by the warrant holders.  If
appropriate, please update your Related Party Transactions section.

 FirstName LastNameChristian Hanke
 Comapany NameOatly Group AB
 May 14, 2021 Page 2
 FirstName LastName
Christian Hanke
Oatly Group AB
May 14, 2021
Page 2
            You may contact Mindy Hooker at (202) 551-3732 or John Cash, Accounting Branch
Chief, at (202) 551-3768 if you have questions regarding comments on the financial statements
and related matters.  Please contact Geoff Kruczek at (202) 551-3641 or Asia Timmons-Pierce at
(202) 551-3754 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Marc Jaffe

CORRESP
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 1271 Avenue of the Americas

New York, New York 10020-1401

Tel: +1.212.906.1200 Fax: +1.212.751.4864

www.lw.com

FIRM / AFFILIATE OFFICES

Beijing

Moscow

Boston

Munich

Brussels

New York

Century City

Orange County

Chicago

Paris

Dubai

Riyadh

 May 11, 2021

Düsseldorf

San Diego

Frankfurt

San Francisco

Hamburg

Seoul

Hong Kong

Shanghai

Houston

Silicon Valley

London

Singapore

Los Angeles

Tokyo

Madrid

Washington, D.C.

Milan

VIA EDGAR AND HAND DELIVERY

 United States Securities and Exchange Commission

Division of Corporation Finance

 100 F Street, N.E.

Washington, D.C. 20549-6010

Attention:        Mandy Hooker

John Cash

 Geoff Kruczek

Asia Timmons-Pierce

Re:       Oatly Group AB

Registration Statement on Form F-1

Filed on April 19, 2021

CIK No. 0001843586

 Ladies and
Gentlemen:

 On behalf of Oatly Group AB, previously referred to as Havre Global AB (the “Company”), we are hereby filing
Amendment No. 1 (“Amendment No. 1”) to the Registration Statement on Form F-1 (Registration No. 333-255344) filed with the Commission on
April 19, 2021 (the “Registration Statement”). The Company previously submitted a Draft Registration Statement on Form F-1 on a confidential basis pursuant to Title I, Section 106 under the
Jumpstart Our Business Startups Act with the Securities and Exchange Commission (the “Commission”) on February 12, 2021, as amended on March 25, 2021 (“Submission No. 2”). Amendment No. 1 has been revised to
reflect the Company’s responses to the comment letter to the Registration Statement received on April 27, 2021 from the staff of the Commission (the “Staff”).

For ease of review, we have set forth below each of the numbered comments of your letter in bold type followed by the Company’s
responses thereto.

 Prospectus Summary, page 1

         May 11, 2021

        Page 2

1.
 Notwithstanding your response to prior comment 1 that you will not be a “controlled company,” it
continues to appear from your disclosure that the PRC will have a significant ownership interest in you and, therefore, have significant influence over decisions that require shareholder approval. If so, please revise to disclose that fact and that
risks to investors.

 Response: The Company respectfully acknowledges the Staff’s comment and has
revised pages 16, 51 and 52 of Amendment No. 1.

 * * *

We hope the foregoing answers are responsive to your comments. Please do not hesitate to contact me by telephone at (212) 906-1281 with any questions or comments regarding this correspondence.

Very truly yours,

/s/ Marc D. Jaffe

 Marc D. Jaffe

 of LATHAM & WATKINS
LLP

cc:
 (via email)

Toni Petersson, Oatly Group AB

Christian Hanke, Oatly Group AB

Ian D. Schuman, Latham & Watkins LLP

Stelios G. Saffos, Latham & Watkins LLP

United States securities and exchange commission logo
April 27, 2021
Christian Hanke
Chief Financial Officer
Oatly Group AB
Stora Varvsgatan 6a
211 19 Malmö
Sweden
Re:Oatly Group AB
Registration Statement on Form F-1
Filed April 19, 2021
File No. 333-255344
Dear Mr. Hanke:
            We have reviewed your registration statement 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 this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
Registration Statement on Form F-1 filed April 19, 2021
Prospectus Summary, page 1
1.Notwithstanding your response to prior comment 1 that you will not be a "controlled
company," it continues to appear from your disclosure that the PRC will have a significant
ownership interest in you and, therefore, have significant influence over decisions that
require shareholder approval.  If so, please revise to disclose that fact and that risks to
investors.
            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.

 FirstName LastNameChristian Hanke
 Comapany NameOatly Group AB
 April 27, 2021 Page 2
 FirstName LastName
Christian Hanke
Oatly Group AB
April 27, 2021
Page 2
            Refer to Rules 460 and 461 regarding requests for acceleration.  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            You may contact Mindy Hooker at (202) 551-3732 or John Cash, Accounting Branch
Chief, at (202) 551-3768 if you have questions regarding comments on the financial statements
and related matters.  Please contact Geoff Kruczek at (202) 551-3641 or Asia Timmons-Pierce at
(202) 551-3754 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Marc Jaffe

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 53rd at Third

 885 Third
Avenue

 New York, New York 10022-4834

 Tel: +1.212.906.1200 Fax:
+1.212.751.4864

 www.lw.com

FIRM / AFFILIATE OFFICES

Beijing

Moscow

Boston

Munich

Brussels

New York

Century City

Orange County

Chicago

Paris

April 19, 2021

Dubai

Riyadh

Düsseldorf

San Diego

Frankfurt

San Francisco

Hamburg

Seoul

Hong Kong

Shanghai

Houston

Silicon Valley

London

Singapore

Los Angeles

Tokyo

Madrid

Washington, D.C.

Milan

 VIA EDGAR AND HAND DELIVERY

United States Securities and Exchange Commission

 Division of
Corporation Finance

 100 F Street, N.E.

 Washington, D.C.
20549-6010

Attention:

Mandy Hooker

 John Cash

 Geoff Kruczek

Asia Timmons-Pierce

Re:

 Oatly Group AB

 Draft
Registration Statement on Form F-1

 Confidentially submitted on March 25, 2021

CIK No. 0001843586

 Ladies and Gentlemen:

On behalf of Oatly Group AB, previously referred to as Havre Global AB (the “Company”), we are hereby filing a
Registration Statement on Form F-1 (the “Registration Statement”). The Company previously submitted a Draft Registration Statement on Form F-1 on
a confidential basis pursuant to Title I, Section 106 under the Jumpstart Our Business Startups Act with the Securities and Exchange Commission (the “Commission”) on February 12, 2021, as amended on March 25,
2021 (“Submission No. 2”). The Registration Statement has been revised to reflect the Company’s responses to the comment letter to Submission No. 2 received on April 8, 2021
from the staff of the Commission (the “Staff”).

 For ease of review, we have set forth below each of the numbered
comments of your letter in bold type followed by the Company’s responses thereto.

 Summary, page 1

1.
 We note your disclosure in footnote 1 on page 121 that CR Holdings is indirectly and wholly owned by China
Resources Company Limited and that the State-owned Assets Supervision and Administration Commission of the State Council of the People’s Republic of China performs the duty of investor of China Resources Company Limited on behalf of the State
Council. Please revise your disclosures on pages 18 and 50 to reflect the PRC’s indirect ownership interest in your company.

 April 19, 2021

Page 2

 Response: The Company respectfully acknowledges the Staff’s comment and advises
the Staff that the Company no longer expects to be a “controlled company” following the completion of the offering and accordingly has removed these references from the Registration Statement.

Liquidity and Capital Resources, page 77

2.
 Your disclosures indicate that in spring 2021, you will open your second U.S. facility and that three
additional facilities in Singapore, Maanshan, China and Peterborough, the United Kingdom are currently under construction or in the planning stages. Given that these appear to be material expenditures, please revise your disclosure to discuss the
estimated cost and time frame of these projects and how you plan to finance them.

 Response: The Company
respectfully acknowledges the Staff’s comment and has revised page 79 of the Registration Statement.

 Additional Listing Agreement, page 122

3.
 We note your response to prior comment 7. Please revise to address the first sentence of that comment.

 Response: The Company respectfully acknowledges the Staff’s comment and has revised page 131 of the
Registration Statement.

 Consolidated Statement of Operations, page F-3

4.
 Please relocate the subtotal line from below gross profit to above gross profit to ensure it is clear that
gross profit is the net of revenue and cost of goods sold.

 Response: The Company respectfully acknowledges
the Staff’s comment and has revised page F-3 of the Registration Statement.

 Notes to the Consolidated
Financial Statements

 33. Events after the end of the reporting period, page F-50

5.
 Please revise your filing to disclose the date when the financial statements were authorized for issue and
who gave that authorization. Refer to paragraph 17 of IAS 10.

 Response: The Company respectfully acknowledges
the Staff’s comment and has revised page F-8 of the Registration Statement.

 * * *

We hope the foregoing answers are responsive to your comments. Please do not hesitate to contact me by telephone at (212) 906-1281 with any questions or comments regarding this correspondence.

 April 19, 2021

Page 3

Very truly yours,

 /s/ Marc D. Jaffe

 Marc D. Jaffe

 of LATHAM & WATKINS
LLP

cc:
 (via email)

Toni Petersson, Oatly Group AB

Christian Hanke, Oatly Group AB

Ian D. Schuman, Latham & Watkins LLP

Stelios G. Saffos, Latham & Watkins LLP

United States securities and exchange commission logo
April 8, 2021
Christian Hanke
Chief Financial Officer
Oatly Group AB
Stora Varvsgatan 6a
211 19 Malmö
Sweden
Re:Oatly Group AB
Amendment No. 1 to
Draft Registration Statement on Form F-1
Submitted March 25, 2021
CIK No. 0001843586
Dear Mr. Hanke:
            We have reviewed your amended draft registration statement 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 this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
            After reviewing the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Amendment No. 1 to Confidential Draft Registration Statement on Form F-1 submitted March
25, 2021
Summary, page 1
1.We note your disclosure in footnote 1 on page 121 that CR Holdings is indirectly and
wholly owned by China Resources Company Limited and that the State-owned Assets
Supervision and Administration Commission of the State Council of the People’s
Republic of China performs the duty of investor of China Resources Company Limited on
behalf of the State Council.  Please revise your disclosures on pages 18 and 50 to reflect
the PRC's indirect ownership interest in your company.

 FirstName LastNameChristian Hanke
 Comapany NameOatly Group AB
 April 8, 2021 Page 2
 FirstName LastName
Christian Hanke
Oatly Group AB
April 8, 2021
Page 2
Liquidity and Capital Resources, page 77
2.Your disclosures indicate that in spring 2021, you will open your second U.S. facility and
that three additional facilities in Singapore, Maanshan, China and Peterborough, the
United Kingdom are currently under construction or in the planning stages.  Given that
these appear to be material expenditures, please revise your disclosure to discuss the
estimated cost and time frame of these projects and how you plan to finance them.
Additional Listing Agreement, page 122
3.We note your response to prior comment 7.  Please revise to address the first sentence of
that comment.
Consolidated Statement of Operations, page F-3
4.Please relocate the subtotal line from below gross profit to above gross profit to ensure it
is clear that gross profit is the net of revenue and cost of goods sold.
Notes to the Consolidated Financial Statements
33. Events after the end of the reporting period, page F-50
5.Please revise your filing to disclose the date when the financial statements were
authorized for issue and who gave that authorization.  Refer to paragraph 17 of IAS 10.
            You may contact Mindy Hooker at (202) 551-3732 or John Cash, Accounting Branch
Chief, at (202) 551-3768 if you have questions regarding comments on the financial statements
and related matters.  Please contact Geoff Kruczek at (202) 551-3641 or Asia Timmons-Pierce at
(202) 551-3754 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Marc Jaffe

United States securities and exchange commission logo
March 11, 2021
Christian Hanke
Chief Financial Officer
Havre Global AB
Stora Varvsgatan 6a
211 19 Malmö
Sweden
Re:Havre Global AB
Confidential Draft Registration Statement on Form F-1
Submitted February 12, 2021
CIK No. 0001843586
Dear Mr. Hanke:
            We have reviewed your draft registration statement 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 this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
            After reviewing the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Confidential Draft Registration Statement on Form F-1 submitted February 12, 2021
Dilution, page 64
1.Please revise to disclose how the numbers and percentages in the table on page 65 would
change assuming the exercise of all outstanding warrants.
Expand global production capacity, page 72
2.Please disclose the source of funds you are using and intend to use to complete the
production capacity expansion referenced in your disclosure, the amounts you have
already paid and the amounts remaining to be paid.  Also revise the disclosure in the first
two paragraphs on page 79, as appropriate, to reflect the obligations that you have and will

 FirstName LastNameChristian Hanke
 Comapany NameHavre Global AB
 March 11, 2021 Page 2
 FirstName LastName
Christian Hanke
Havre Global AB
March 11, 2021
Page 2
have as a result of the planned expansion.
Driving the global appetite . . ., page 86
3.Please clarify what you mean by the "highest amount of value growth" and "value share,"
as those terms are used in the first two bullets of this section.
4.Please revise the last full paragraph on page 87 to clarify how "continued investment in
production, brand awareness, new markets and product development" resulted in the
margins and losses to which you refer.
Supply Chain Operations, page 104
5.We note your disclosure on page 22 that as of December 31, 2020 you had three suppliers
for the oats used in your products.  Please disclose whether you have agreements with
your suppliers.  Please describe the terms of any such agreements.
Principal and Selling Shareholders, page 118
6.For each entity listed in the table, please identify the natural persons who have or share
voting and/or dispositive power or the right to receive the economic benefit of the
securities.  Please also tell us why China Resources Verlinvest Health Investment Ltd. is
not included in the table, given your disclosure on page F-41 that it is the "controlling
party" and owns 100% of the shares of Nativus Company Limited.
Additional Listing Agreement, page 119
7.Please revise to clarify whether "[y]our shareholders or their affiliates [are] owned or
controlled by, or otherwise affiliated with, a foreign state, government or political party"
and, if so, the identify of that state, government or party.  Please also revise to clarify
whether there are any existing or contemplated laws, regulations or policies that, in light
of your current and planned operations and composition of management, directors and
shareholders, would or could reasonably likely result in a "material adverse effect," as
defined in your disclosure.  Add any appropriate risk factors.
Shareholders' Agreement, page 119
8.Please revise to clarify who is a party to this agreement, the nature and amount of any
direct or indirect material interest and the rights and obligations of the parties under the
agreement.
Related Party Transaction Policy, page 120
9.Please describe the policies and procedures for the review and approval or ratification of
related party transactions.

 FirstName LastNameChristian Hanke
 Comapany NameHavre Global AB
 March 11, 2021 Page 3
 FirstName LastName
Christian Hanke
Havre Global AB
March 11, 2021
Page 3
Exclusive Forum, page 122
10.Please revise to clarify to whom this provision will apply.  We note, for example, the risk
factor on page 54 addresses only holders of ADSs.  Is this provision limited to holders of
your ordinary shares?  Please also add a risk factor discussing the risks to investors
resulting from this provision, if adopted at the meeting to which you refer.  Please disclose
any uncertainty as to whether courts would enforce the provision.  In this regard, we note
that Section 22 of the Securities Act creates concurrent jurisdiction for federal and state
courts over all suits brought to enforce any duty or liability created by the Securities Act
or the rules and regulations thereunder.
Exhibits
11.We note the disclosure on page (ii) regarding the survey you commissioned and that you
cite that survey in this registration statement.  Please file the consent required by Rule 436
of Regulation C.
12.Please file as exhibits the employment arrangements mentioned on pages 116-117.
General
13.Please supplementally provide us with copies of all written communications, as defined in
Rule 405 under the Securities Act, that you, or anyone authorized to do so on your behalf,
present to potential investors in reliance on Section 5(d) of the Securities Act, whether or
not they retain copies of the communications.  Please contact the staff member associated
with this review for guidance on how to submit those materials.
            You may contact Mindy Hooker at (202) 551-3732 or John Cash, Accounting Branch
Chief, at (202) 551-3768 if you have questions regarding comments on the financial statements
and related matters.  Please contact Geoff Kruczek at (202) 551-3641 or Asia Timmons-Pierce at
(202) 551-3754 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Marc Jaffe