September 4, 2018

Richard Contreras
Chief Financial Officer
Fresh Del Monte Produce Inc.
241 Sevilla Avenue
Coral Gables, Florida 33134

       Re: Fresh Del Monte Produce Company Inc.
           Form 10-Q for the Quarter Ended June 29, 2018
           Response Dated August 17, 2018
           File No. 333-07708

Dear Mr. Contreras:

       We have reviewed your August 17, 2018 response to our comment letter and
have the
following comment. 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 comment 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
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. Unless we note otherwise, our references to prior comments are to
comments in our
August 9, 2018 letter.

Form 10-Q for the Quarter Ended June 29, 2018

Notes to the Consolidated Financial Statements
3. Summary of Significant Accounting Policies
Revenue Recognition, page 8

1.    We note from your response to our prior comment 1 that you believe
      your disclosure based on aggregated reportable segments as included in
Note 16 is
      sufficient to meet the requirements of ASC 606 in terms of disaggregated
revenue
      disclosures because your contracts with your customers do not differ
across fruit
      products. However, the guidance in ASC 606-10-55-90 indicates that when
selecting the
      type of category to use to disaggregate revenue, you should also consider
how information
 Richard Contreras
Fresh Del Monte Produce Inc.
September 4, 2018
Page 2
         about your revenue has been presented for other purposes including
among other factors,
         disclosures presented outside your financial statements such as in
earnings releases,
         annual reports or investor presentations. In this regard, we note that
you have provided
         revenue amounts on a further disaggregated basis than your reportable
segments in
         earnings releases and in the front section of your Form 10K. The
guidance also gives
         examples of categories that might be appropriate which includes type
of contract, but does
         not limit the categories based on customer contracts. Please provide
us further analysis
         for why you believe product types such as pineapples, fresh-cut
product, avocados,
         melons, and non-tropical produce have similar economic factors in the
nature, amount,
         timing and uncertainty of revenue and cash flows and therefore do not
need to be
         disaggregated under the guidance in ASC 606. Alternatively, please
further disaggregate
         your revenue in the notes to the financial statements under ASC
606-10-50-5. Refer also
         to the guidance in ASC 606-10-55-89 through 91.
      You may contact Melissa Gilmore at (202) 551-3777 or Claire Erlanger at
(202) 551-
3301 with any questions.



FirstName LastNameRichard Contreras                          Sincerely,
Comapany NameFresh Del Monte Produce Inc.
                                                             Division of
Corporation Finance
September 4, 2018 Page 2                                     Office of
Transportation and Leisure
FirstName LastName