September 26, 2018

Ron Edmonds
Co-Controller
DowDuPont Inc.
c/o The Dow Chemical Company
2211 H.H. Dow Way
Midland, MI 48674

Jeanmarie Desmond
Co-Controller
DowDuPont Inc.
c/o E.I. du Pont de Nemours and Company
974 Centre Road
Wilmington, DE 19805

       Re: DowDuPont Inc.
           Form 10-K for the Year Ended December 31, 2017
           Filed February 15, 2018
           Definitive Proxy Statement on Schedule 14A
           Filed March 16, 2018
           File No. 001-38196

Dear Mr. Edmonds:

       We have reviewed your filing and have the following comments. In some of
our
comments, we may ask you to provide us with information so we may better
understand your
disclosure.

       Please respond to these comments 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
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.
 Ron Edmonds
FirstName LastNameRon Edmonds
DowDuPont Inc.
Comapany 26, 2018
September NameDowDuPont Inc.
September 26, 2018 Page 2
Page 2
FirstName LastName

Form 10-K for the Year Ended December 31, 2017

General, page 1

1.       In a letter to us dated May 13, 2015, The Dow Chemical Company
discussed its business
         with Sudan. We also are aware of news articles reporting that Emirates
SkyCargo uses a
         DuPont product to protect sensitive cargo in transit, and that
Emirates SkyCargo offers
         services to Sudan. As you know, Sudan is designated as a state sponsor
of terrorism by
         the State Department and is subject to U.S. export controls. You do
not include disclosure
         about Sudan in the Form 10-K. Please describe to us the nature and
extent of your past,
         current and anticipated contacts with Sudan since the May 2015 letter,
including any
         contacts with its government, whether through subsidiaries,
affiliates, customers or other
         direct or indirect arrangements. Please also discuss the materiality
of those contacts, in
         quantitative terms and in terms of qualitative factors that a
reasonable investor would
         deem important in making an investment decision. Tell us the
approximate dollar
         amounts of revenues, assets and liabilities associated with Sudan for
the last three fiscal
         years and the subsequent interim period. Address for us the potential
impact of the
         investor sentiment evidenced by divestment and similar initiatives
that have been directed
         toward companies that have operations associated with a
U.S.-designated state sponsor of
         terrorism.
Consolidated Financial Statements
Note 3 - Business Combinations, page 95

2.       Please reconcile the pro forma adjustments used to calculate pro forma
net income for the
         years ended December 31, 2017 and 2016 under ASC 805, as disclosed on
page 100, with
         the pro forma amounts presented on pages 44 and 45.
Note 13 - Goodwill and Other Intangible Assets, page 124

3.       We note you recorded a goodwill impairment charge in the Coatings &
Performance
         Monomers reporting unit of $1,491 million in the fourth quarter of
2017. Please more
         fully explain to us the specific facts and circumstances that resulted
in an impairment
         charge during the fourth quarter of 2017 and address the following:
           Explain any changes to this reportable segment and reporting unit,
including the
             allocation of goodwill, that resulted from the Merger and the
related reallocation of
             goodwill;
           Tell us if you performed any interim impairment tests between your
2016 and 2017
             annual impairment tests and explain why or why not;
           Tell us the differences between the significant assumptions and
estimates you used to
             determine the estimated fair values of this reporting unit in your
2017 and 2016 annual
             impairment tests; and
           Explain when the changed circumstances related to this reporting
unit occurred and
 Ron Edmonds
FirstName LastNameRon Edmonds
DowDuPont Inc.
Comapany 26, 2018
September NameDowDuPont Inc.
September 26, 2018 Page 3
Page 3
FirstName LastName
             tell us what, if any, cautionary disclosures regarding a potential
material goodwill
             impairment charge related to this reporting unit you provided
prior to your fiscal year
             2017 Form 10-K.
Note 24 - Segments and Geographic Regions, page 179

4.       Please more fully explain to us how you determined your new operating
segments,
         including how you integrated the business components of DuPont, how
segment
         management was realigned, how you identified your chief operating
decision maker
         (CODM), and what information is used by management to allocate
resources and assess
         performance.
5.       We note your measure of profit/loss for segment reporting purposes is
pro forma
         Operating EBITDA (for the period of January 1, 2017 through August 31,
2017 and the
         twelve months ended December 31, 2016) since it is the manner in which
your CODM
         assesses performance and allocates resources. Please address the
following:
           Provide us details of the pro forma adjustments used to calculate
pro forma Operating
             EBITDA for 2017 and 2016, similar to the tabular presentations you
provide of
             significant items;
           Clarify your disclosures that the pro forma adjustments include the
elimination of the
             effect of events that are directly attributable to the Merger
Agreement, such as
             transaction costs, and events not expected to have a continuing
impact on combined
             results, such as inventory step-up costs, since it appears to us
that these amounts are
             already excluded and identified as significant items;
           Reconcile the pro forma adjustments used to calculate pro forma
Operating EBITDA
             for 2017 and 2016 on page 186 with the pro forma adjustments on
pages 44 and 45;
             and
           Explain why no historical measures of profit/loss by segment are
presented.

Definitive Proxy Statement on Schedule 14A
Compensation Discussion and Analysis, page 30

6.       We note that you benchmarked each component of your Named Executive
Officers' target
         pay to your disclosed peer group. In future filings, please disclose
the components used
         for benchmarking and the level at which you benchmark. Please refer to
Item
         402(b)(2)(xiv) 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
action by the staff.
 Ron Edmonds
DowDuPont Inc.
September 26, 2018
Page 4

       You may contact Dale Welcome at 202-551-3865 or Anne McConnell at
202-551-3709 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Sergio Chinos at 202-551-7844 or Jay Ingram at 202-551-3397 with any
other questions.



                                                         Sincerely,
FirstName LastNameRon Edmonds
                                                         Division of
Corporation Finance
Comapany NameDowDuPont Inc.
                                                         Office of
Manufacturing and
September 26, 2018 Page 4                                Construction
FirstName LastName