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                             December 22, 2023

       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
                                                            File No. 001-35573

       Dear John Srivisal:

                                                        We have reviewed your
filing 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.

       Form 10-K

       Mining Operations, page 27

   1.                                                   The summary disclosures
should encompass all your properties, including both material
                                                        and non-material
properties, and should appear in advance of and incremental to, the
                                                        individual property
disclosures. The requirements for individual property disclosures are
                                                        more extensive and
detailed in comparison and are applicable for material properties, as
                                                        determined pursuant to
Item 1301 of Regulation S-K. For example, the summary
                                                        disclosures should
describe the locations of each operating, development, and exploration
                                                        property to comply with
Item 1303(b)(2)(ii)(A); while the individual property disclosures
                                                        should include
comparable details along with a map for each property, showing its
                                                        particular location,
that is accurate to within one mile, using an easily recognizable
                                                        coordinate system, to
comply with Item 1304(b)(1)(i). Please revise your filing to include
                                                        and differentiate
between the summary and individual property disclosures to comply with
                                                        the aforementioned
guidance.
       Mineral Sands - South Africa and Australia, page 30

   2.                                                   Please revise your
filing to report each individual property   s production by product such
 John Srivisal
FirstName  LastNameJohn   Srivisal
Tronox Holdings   plc
Comapany22,
December   NameTronox
               2023     Holdings plc
December
Page 2     22, 2023 Page 2
FirstName LastName
         as heavy metals, ilmenite, rutile, leucoxene, and zircon. as required
by Item 1303(b)(2)(i)
         of Regulation S-K.
Heavy Metal Reserves, page 32

3.       Please include the commodity price used, metallurgical recovery, and
the cutoff grade
         with your resource and reserve disclosures as required by Item
1303(b)(3) of Regulation
         S-K.
4.       Please state whether your qualified persons (QP   s) are employees of
your company and
         provide the additional information required by Item 1302(b)(5) of
Regulation S-K.
Tronox Mineral Sands - 2022 Resources, page 34

5.       Please clearly state your mineral resources are exclusive of reserves
as required by Item
         1303(b)(3) of Regulation S-K.
6.       Please modify your filing and provide a more detailed reconciliation
of your
         resources/reserves as reported this year to last year, as required by
Item 1303(e) of
         Regulation S-K.
7.       Please modify your filing here and elsewhere to state the book value
of your material
         properties as required by Item 1304(b)(2)(iii) of Regulation S-K.
Exhibits 96.1, 96.2, 96.3, and 96.4
Property Description, page E-1

8.       Please modify your exhibits and locate your property within one-mile
using an easily
         recognizable coordinate system as required by Item
601(b)(96)(iii)(B)(3)(i) of Regulation
         S-K.
Exhibits 96.1, 96.2, 96.3, and 96.4
Geological Setting, Mineralisation and Deposit, page E-2

9.       Please modify your filings and ensure you have provided at least one
stratigraphic column
         and one cross-section of the local geology as required by Item
601(b)(96)(iii)(B)(6)(iii) of
         Regulation S-K.
Exhibits 96.1, 96.2, 96.3, and 96.4
Sample Preparation, Analyses and Security, page E-3

10.      Please modify your filing and provide the opinion of the QP regarding
the adequacy of the
         sample preparation, security, and analytical procedures as required by
Item
         601(b)(96)(iii)(B)(8)(iv) of Regulation S-K.
Exhibits 96.1, 96.2, 96.3, and 96.4
Mineral Processing and Metallurgical Testing, page E-4
 John Srivisal
FirstName  LastNameJohn   Srivisal
Tronox Holdings   plc
Comapany22,
December   NameTronox
               2023     Holdings plc
December
Page 3     22, 2023 Page 3
FirstName LastName
11.      We reviewed the Mineral Processing and Metallurgical Testing section
of your technical
         report summary. Please modify your filing to disclose your estimated
metallurgical
         recoveries with the QP   s opinion on the adequacy of the
metallurgical data as required by
         Item 601(b)(96)(iii)(B)(10)(v) of Regulation S-K.
Exhibits 96.1, 96.2, 96.3, and 96.4
Mineral Resource Estimates, page E-5

12.      Please modify your filing and disclose the cutoff grade for your
resource estimates with
         all the parameters used to prepare this calculation. This would
include your commodity
         price, operating costs, and metallurgical recovery. See Item
601(b)(96)(iii)(B)(11)(iii) of
         Regulation S-K.
13.      Please modify your filing and revise your resource and reserve
summaries in your exhibits
         to clarify whether your cutoff grades are a breakeven and
internal/marginal cutoff grade.
14.      Please modify your filing and disclose the QP   s opinion on whether
all issues related to
         resource technical and/or economic factors influencing economic
extraction can be
         resolved with further work. See Item 601(b)(96)(iii)(B)(11)(vii) of
Regulation S-K.
Exhibits 96.1, 96.2, 96.3, and 96.4
Mineral Reserve Estimates, page E-6

15.      Please modify your filing and disclose the cutoff grade for your
reserve estimates along
         with all the parameters used to prepare this calculation. See Item
         601(b)(96)(iii)(B)(12)(iii) of Regulation S-K.
16.      We note you did not state a commodity sales price for your resource
and reserve
         estimates. Please state the price used to determine your
resources/reserves and disclose,
         with particularity, the reasons this price was selected and any
assumptions underlying this
         selection. See Item 601(b)(96)(iii)(B)(12)(iii) of Regulation S-K.
Exhibits 96.1, 96.2, 96.3, and 96.4 A
Mining Methods, page E-7

17.      Please provide annual numerical values for your life of mine
production schedule. This
         would include annual processed ore with associated grades for the life
of mine. See Item
         601(b)(96)(iii)(B)(13) of Regulation S-K
Exhibits 96.1, 96.2, 96.3, and 96.4 A
Processing and Recovery Methods, page E-8

18.      We note your property has been in operation for several years. Please
disclose your
         annual plant throughput and recoveries over the last 3 years. Item
         601(b)(96)(iii)(B)(14)(ii) of Regulation S-K.
Exhibits 96.1, 96.2, 96.3, and 96.4 A
 John Srivisal
FirstName  LastNameJohn   Srivisal
Tronox Holdings   plc
Comapany22,
December   NameTronox
               2023     Holdings plc
December
Page 4     22, 2023 Page 4
FirstName LastName
Market Studies, page E-9

19.      Please provide the relevant market price projections for your life of
mine and include the
         5-year historic prices with your forecast pricing as required by Item
601(b)(96)(iii)(B)(16)
         of Regulation S-K.
Exhibits 96.1, 96.2, 96.3, and 96.4 A
Environmental studies, permitting and plans, negotiations, or agreements with
local individuals
or groups, page E-10

20.      We reviewed the Environmental Studies, Permitting, And Plans,
Negotiations, Or
         Agreements with Local Individuals or Groups section of your technical
report summary.
         Please modify your filing and include the QP   s opinion as to the
adequacy of current plans
         for environmental compliance, permitting, and addressing issues with
local individuals or
         groups required by Item 601(b)(96)(iii)(B)(17)(vi) of Regulation S-K.
Exhibits 96.1, 96.2, 96.3, and 96.4 A
Capital and Operating Cost, page E-11

21.      Please revise to provide a tabulation of all the operating and capital
costs for your life of
         mine used to prepare your economic analysis. See Item
601(b)(96)(iii)(B)(18)(i) of
         Regulation S-K.
22.      Please modify your filing and define the accuracy of your capital and
operating costs
         estimates as required by Item 601(b)(96)(iii)(B)(18)(i) of Regulation
S-K.
23.      Please modify your filings to disclose your closing/reclamation costs
as required by Item
         601(b)(96)(iii)(B)(18)(i) of Regulation S-K.
Exhibits 96.1, 96.2, 96.3, and 96.4 A
Economic Analysis, page E-12

24.      We note you did not disclose an economic analysis for your reserves in
this section.
         Please modify your filing to provide an annual cash flow, summarizing
the results on an
         after-tax basis. Your financial analysis should disclose your
production, prices, revenues,
         capital, sustaining capital, reclamation, operating costs, royalties,
taxes, DD&A, pre- and
         post-tax cash flows for the life of your property   s reserves. This
information should be
         clearly related to information developed and disclosed in previous
sections, such as
         reserve quantities, mine/plant recoveries, prices, operating costs,
capital expenditures,
         royalties, taxes, and other line items necessary to define your
after-tax cash flow. See
         Item 601(b)(96)(iii)(B)(19)(ii) of Regulation S-K.
25.      Please include a sensitivity analysis and discuss the impact on your
cash flow analysis as
         required by Item 601(b)(96)(iii)(B)(19)(iii) of Regulation S-K.
       We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
 John Srivisal
Tronox Holdings plc
December 22, 2023
Page 5

action by the staff.

       Please contact Ken Schuler at 202-551-3718 or Craig Arakawa at
202-551-3650 with any
questions regarding the comments. Please contact Jeanne Baker at 202-551-3691
or Terence
O'Brien at 202-551-3355 if you have any other questions.



                                                        Sincerely,
FirstName LastNameJohn Srivisal
                                                        Division of Corporation
Finance
Comapany NameTronox Holdings plc
                                                        Office of Industrial
Applications and
December 22, 2023 Page 5                                Services
FirstName LastName