October 11, 2024

Brian Dykes
Executive Vice President and Chief Financial Officer
United Parcel Service, Inc.
55 Glenlake Parkway, NE
Atlanta, GA 30328

       Re: United Parcel Service, Inc.
           Form 10-K for the Fiscal Year ended December 31, 2023
           Filed February 20, 2024
           File No. 001-15451
Dear Brian Dykes:

        We have reviewed your September 26, 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 July 25,
2024 letter.

Form 10-K for the Fiscal Year ended December 31, 2023
Management's Discussion and Analysis, page 23

1.     We note your response to prior comment two indicating that
transformation strategy
       costs excluded in calculating your non-GAAP measures over the last six
years relate
       to various initiatives that were undertaken to adjust the number of
employees to align
       with the needs of the business, to develop or refine business processes,
and to upgrade
       or enhance technology utilized in fulfilling the needs of the business.
You mention
       various circumstances precipitating these initiatives such as changing
competitive
       landscapes, inflationary pressures, changes in consumer behaviors,
normalization of
       volumes, and volume diversions which you attribute to labor
negotiations.

       You indicate that you do not consider the related costs to be ordinary
because each
       plan involved separate and distinct activities that would span multiple
periods
 October 11, 2024
Page 2

       and were not expected to drive incremental revenue, and because the
scope of the
       initiatives exceeded that of routine, ongoing efforts to enhance
profitability; although
       it appears that your initiatives were nevertheless intended to maintain
or enhance
       performance by addressing functional needs and by reducing costs.

       We understand from your response that you propose to include additional
details
       about these initiatives in future disclosures, such as the costs, scope,
duration and
       status of the projects, and further explanation about why you exclude
the costs in
       compiling the various non-GAAP measures. We believe that such
disclosures should
       also clearly articulate the rationale and objectives, include expected
and actual costs,
       as applicable, and describe any measurable results in relation to the
goals.

       For example, the disclosure on page 26, explaining that you do not
consider
       transformation strategy costs when evaluating the operating performance
of
       the business units, or in making resource allocation decisions, should
be expanded to
       clarify how you view the importance of the initiatives in adapting
personnel levels and
       systems to the evolving business environment, and to explain how
assessments of
       operating performance, and of the effectiveness and utility of business
processes,
       precipitated the allocation of resources to these transformation
initiatives.

       The extent to which the initiatives have been successful in meeting the
transformation
       objectives, as to modernization, quality enhancement, and efficiencies,
and in relation
       to maintaining or enhancing operating performance, should be addressed.

       Please submit the revisions that you propose to address prior comment
two, and the
       additional concerns outlined above, within the disclosures on pages 26,
31, 34, 36, and
       40, under Items Affecting Comparability, and pertaining to the effects
on operating
       and other expenses of the business segments and consolidated entity.


       Please contact Yong Kim at 202-551-3323 or Karl Hiller at 202-551-3686
if you have
questions regarding comments on the financial statements and related matters.



                                                             Sincerely,

                                                             Division of
Corporation Finance
                                                             Office of Energy &
Transportation