January 10, 2025

Elizabeth Gonzalez-Sussman
Partner
Air Products & Chemicals, Inc.
Skadden, Arps, Meagher & Flom LLP
One Manhattan West
New York, New York 10001

       Re: Air Products & Chemicals, Inc.
           DEFA14A filed January 7, 2025
           SEC File No. 1-04534
Dear Elizabeth Gonzalez-Sussman:

      We have reviewed your filing and have the following comment. In our
comment, we
may ask you to provide us with information so we may better understand your
disclosure.

        Please respond to this comment by providing the requested information
or advise us
as soon as possible when you will respond. If you do not believe our comment
applies to your
facts and circumstances, please tell us why in your response.

       After reviewing your response to this comment, we may have additional
comments.

DEFA14A filed January 7, 2024
Press Release dated January 7, 2025, page 1

1.     We note the statement that you have    industry leading margins    based
on Adjusted
       EBITDA margin. Please tell us how this disclosure complies with Item
10(e) of
       Regulation S-K and Question 102.10(a) of the Compliance & Disclosure
       Interpretations regarding Non-GAAP Financial Measures. Please also tell
us how you
       considered Item 10(e) of Regulation S-K with regards to your disclosure
of Adjusted
       EPS CAGR.
 January 10, 2025
Page 2

        We remind you that the filing persons are responsible for the accuracy
and adequacy
of their disclosures, notwithstanding any review, comments, action or absence
of action by
the staff. Please direct any questions to Christina Chalk at 202-551-3263.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Mergers &
Acquisitions