United States securities and exchange commission logo February 27, 2024 John Srivisal Chief Financial Officer Tronox Holdings plc 263 Tresser Boulevard , Suite 1100 Stamford, Connecticut 06901 Re: Tronox Holdings plc Form 10-K filed February 22, 2023 Response dated February 2, 2024 File No. 001-35573 Dear John Srivisal: We have reviewed your February 2, 2024 response to our comment letter and have the following comment. 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 December 22, 2023 letter. Form 10-K for the Fiscal Year Ended December 31, 2022 Item 15. Exhibits, Financial Statement Schedules. Exhibits 96.1, 96.2, 96.3, and 96.4, page 106 1. We note your response to comment 24, and that your proposed draft disclosure includes average annual cash flows. Please confirm that your revised technical report summaries will include cash flows on an annual basis, rather than average annual basis, to comply with Item 601(b)(96)(iii)(B)(19)(iii) of Regulation S-K. Please contact John Coleman at 202-551-3610 or Craig Arakawa at 202-551-3650 with any questions regarding the comment. Please contact Jeanne Baker at 202-551-3691 or Terence O'Brien at 202-551-3355 if you have any other questions. John Srivisal Tronox Holdings plc February 27, 2024 Page 2 Sincerely, FirstName LastNameJohn Srivisal Division of Corporation Finance Comapany NameTronox Holdings plc Office of Industrial Applications and February 27, 2024 Page 2 Services FirstName LastName