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                             March 15, 2024

       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, 2023
                                                            Filed October 2,
2023
                                                            File No. 001-37974

       Dear Kevin Chin:

              We have reviewed your March 7, 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 March 1, 2024
       letter.

       Form 20-F for the Fiscal Year ended June 30, 2023

       Operating and Financial Review and Prospects
       A. Operating Results
       Overview
       Non-IFRS Financial Information, page 3

   1.                                                   We have reviewed the
clarifying disclosures proposed in your response to prior comment
                                                        1, regarding the
circumstances underlying various adjustments made in computing your
                                                        non-IFRS measure, and
have the following additional points for you to address.

                                                              Confirm, if true,
that amounts on the line item    Restructuring and other non-recurring
                                                            costs    in your
non-IFRS reconciliation include all of the components that are listed in
                                                            the corresponding
table within Note 8 on page F-26 of the amendment that you filed
 Kevin Chin
VivoPower International PLC
March 15, 2024
Page 2
              on February 21, 2024. However, if this is the not the case,
please clarify the
              composition and explain your rationale for any selectivity in
this regard.

                Given your characterization of the $3.9 million charge for an
extreme weather event,
              and the $1.9 million charge for border closures impacting your
Blue Grass project as
              non-recurring costs, explain to us why these are not included in
the table referenced
              in the preceding point, explain how these are presented in your
income statement, and
              discuss your rationale for the apparent inconsistency in
characterizing these events.

                Expand your discussion and analysis under the Income Statement
from continuing
              operations section beginning on page 6 of your most recent
amendment to more
              thoroughly discuss the circumstances underlying the two events
referenced in the
              preceding point, as well as the provision for fiscal refunds; it
should be clear how
              these events have hindered your ability to conduct operations,
and why you consider
              these events to be unique, non-recurring, and uncharacteristic of
normal operations.

                Reposition items that are incremental to the Restructuring and
other non-recurring
              costs reported in Note 8 on page F-26 of the amendment that you
filed on February
              21, 2024 as separate adjustments in your non-IFRS reconciliation.

                Expand your footnotes to the reconciliation as necessary to
clarify the nature of
              any material components of the adjustments sufficiently to
understand why you
              believe investors should consider the charges separately from
your non-
              IFRS measure, whether you regard the charges as avoidable or
unavoidable, and the
              reasons you do not expect these or any similar charges to
reoccur.

       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.



FirstName LastNameKevin Chin                                    Sincerely,
Comapany NameVivoPower International PLC
                                                                Division of
Corporation Finance
March 15, 2024 Page 2                                           Office of
Energy & Transportation
FirstName LastName