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                             March 1, 2021

       Kevin Chin
       Chief Executive Officer
       VivoPower International PLC
       The Scalpel, 18th Floor, 52 Lime Street
       London EC3M 7AF
       United Kingdom

                                                        Re: VivoPower
International PLC
                                                            Form 20-F for the
Fiscal Year ended June 30, 2020
                                                            Filed September 8,
2020
                                                            File No. 001-37974

       Dear Mr. Chin:

              We have limited our review of your filing to the financial
statements and related
       disclosures 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.

       Form 20-F for the Fiscal Year ended June 30, 2020

       Information on the Company
       History and Development of the Company, page 22

   1.                                                   We note your disclosure
stating that in August 2020 you announced plans to enter the
                                                        commercial electric
vehicle market "...to provide sustainable energy solutions for light
                                                        electric vehicles" and
we see that you have since made various representations about
                                                        revenues to be earned
under a contract with GB Auto in Australia, in press releases filed
                                                        on Form 6-K, December
23, 2020, January 25, 2021, February 2, 2021, and February 24,
                                                        2021, including your
half-year report and presentation.

                                                        In the half-year
report, you state that the GB Auto partnership is    worth an estimated $250
                                                        million    and that
revenue "from the agreement    is expected to be at least US$250 million
                                                        over the initial four
years. You disclose that GB Auto is expected to purchase at least
 Kevin Chin
VivoPower International PLC
March 1, 2021
Page 2
         2,000 Tembo electric conversion kits in the first four years of the
agreement, which seems
         to imply that you are expecting to record $125,000 in revenue for each
conversion kit sold
         under the contract. However, in some instances you appear to qualify
the expectation for
         revenues by stating       when combined with the value of the
converted Toyota vehicles.

         Tell us how you have considered both the revenues and the costs of
providing products
         and services under the contract in determining the worth of the
contract that you report.
         Provide us with details of the specific products and/or services to be
provided, and explain
         how you have formulated an expectation for $250 million in revenues
over the four year
         period. Please submit an analysis of the contract provisions under
IFRS 15; identify
         your performance obligations, explain how you will be measuring
progress, and
         determining and allocating the transaction price.

         If your contract includes the resale of vehicles, also explain how you
have established
         your role as a principal in these transactions based on the guidance
in paragraphs B34-B38
         of IFRS 15. Please submit the contract for our review along with your
response.
2.       We note your October 9, 2020 press release states that you purchased
your initial 51%
         interest in Tembo for US$4.7 million, and your February 2, 2021 press
release states that
         you acquired the remaining 49% interest by paying US$2.2 million and
issuing 15,793
         VivoPower shares, having an apparent combined value of about US$2.4
million.

         Please submit the contract(s) governing these transactions, including
any option to acquire
         the remining interest for our review. Please explain how the purchase
price of both the
         initial and remaining interests were determined, and how the $250
million value ascribed
         to the contract with GB Auto was or was not considered and reflected
in the terms, along
         with your rationale. Please describe the status of initiatives to
secure the contract with GB
         Auto at the time of negotiating your initial investment.
       In closing, 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.

        You may contact Joseph Klinko - Staff Accountant, at (202) 551-3824, or
Lily Dang -
 Staff Accountant, at (202) 551-3867 with any questions.



FirstName LastNameKevin Chin                                   Sincerely,
Comapany NameVivoPower International PLC
                                                               Division of
Corporation Finance
March 1, 2021 Page 2                                           Office of Energy
& Transportation
FirstName LastName