May 30, 2025

Scott Kirkland
Chief Financial Officer
Ecolab, Inc.
1 Ecolab Place
St. Paul, MN 55102

        Re: Ecolab, Inc.
            Form 10-K for the fiscal year ended December 31, 2024
            Filed February 21, 2025
            Response Dated May 7, 2025
            File No. 001-09328
Dear Scott Kirkland:

       We have reviewed your May 7, 2025 response to our comment letter and
have the
following comments.

       Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this letter, we may have additional
comments.
Unless we note otherwise, any references to prior comments are to comments in
our April 28,
2025 letter.

Form 10-K for the fiscal year ended December 31, 2024
17. Revenues, page 90

1.     We have reviewed your response to comment 1 and have the following
additional
       comments. Please provide us the full and complete 2024 Executive
Committee review
       presentation used for evaluating the performance of operating segments.
2.     Please provide us a further break-out of revenue between (i) product
revenue, (ii) sold
       equipment revenue, (iii) service revenue, and (iv) lease equipment
revenue, for each
       of the Water, Food & Beverage, and Paper operating segments, for the
Form 10-K
       periods presented.
3.     Please provide us revenue by geographic region for each of the Water,
Food
       & Beverage, and Paper operating segments, for the Form 10-K periods
presented.
 May 30, 2025
Page 2

4.     Separately for each of the Water, Food & Beverage, and Paper operating
segments,
       please provide us the following information:

             The amount of revenue attributable to the operating segment's
largest customer for
           2024;
             For each of the three customers, identify and describe to us any
multi-year
           agreement provisions related to their contracts;
             For each of the three customers, identify and describe to us the
pricing
           mechanisms contained in their contracts; and
             For each of the three customers, the stand-alone selling price for
the product or
           service that contributed the largest amount of revenue for 2024, the
amount of
           such 2024 revenue, and a description of the product or service.

       Please contact Michael Fay at 202-551-3812 or Li Xiao at 202-551-4391 if
you have
questions regarding comments on the financial statements and related matters.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Industrial
Applications and
                                                           Services