June 7, 2019

Graeme Pitkethly
Chief Financial Officer
Unilever PLC
100 Victoria Embankment
London, England

       Re: Unilever PLC
           Form 20-F for the Fiscal Year Ended December 31, 2018
           Filed March 11, 2019
           File No. 1-4546

Dear Mr. Pitkethly:

       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.

Form 20-F for the Fiscal Year Ended December 31, 2018

Financial Statements
Note 2. Segments, page 82

1.    We note that beginning 2018, the Group has combined its Foods and
Refreshment
      operating segments to align with the new structure under which the
business is managed.
      Please tell us the specific details of this new structure and explain how
you determined
      your new reportable segments. Describe in detail any relevant changes in
the financial
      operating data of your Foods and Refreshment businesses that is now
reviewed by your
      chief operating decision maker, which is Unilever Leadership Executive
(ULE) relative to
      the corresponding data the ULE received in 2017. Correlate the change in
reportable
      segments with the applicable guidance in IFRS 8. Quantify the measures
used to assess
      the economic similarity of operating segments, if applicable. In this
regard, we note the
      materially different underlying operating margins of Foods vs.
Refreshment reported in
      your Form 20-F for the year ended December 31, 2017.
 Graeme Pitkethly
Unilever PLC
June 7, 2019
Page 2
2.       Please tell us what consideration was given to providing revenues for
products and
         services, or each group of similar products and services, in
accordance with IFRS 8.32. In
         this regard, we note that under the Beauty & Personal Care segment you
refer to hair care,
         skin cleansing and deodorants, in Foods & Refreshment you refer to
foods, ice cream and
         beverages categories and a foodservice business and in Home Care you
refer to four
         consumer-centric categories.
        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 Jenn Do at (202) 551-3743 or Jeanne Baker at (202)
551-3691 if you
have any questions.



                                                              Sincerely,
FirstName LastNameGraeme Pitkethly
                                                              Division of
Corporation Finance
Comapany NameUnilever PLC
                                                              Office of
Manufacturing and
June 7, 2019 Page 2                                           Construction
FirstName LastName