April 28, 2025

Scott Kirkland
Chief Financial Officer
Ecolab, Inc.
1 Ecolab Place
St. Paul, MN 55102

        Re: Ecolab, Inc.
            Form 10-K for the fiscal year ended December 31, 2024
            Filed February 21, 2025
            Response Dated April 17, 2025
            File No. 001-09328
Dear Scott Kirkland:

       We have reviewed your April 17, 2025 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 April 7,
2025 letter.

Form 10-K for the fiscal year ended December 31, 2024
17. Revenues, page 90

1.     We have reviewed your response to comment 3. Please provide us further
information
       and analysis as it relates to your consideration of disaggregation of
revenues
       attributable to individual operating segments. For example, please
evaluate in further
       detail under ASC 606-10-55-90 your presentation of separate narrative
discussions of
       your operating segment sales, including a reference to sales growth
percentage as a
       header, in your Fourth Quarter 2024 Supplemental, and your presentation
of
       discussions of operating segment revenues in MD&A. Please also provide
us the
       actual company specific information you considered as part of your
       overall assessment under ASC 606-10-50-5 and 55-89 through 55-91,
including the
       break-out of product and sold equipment revenue and service and lease
equipment
 April 28, 2025
Page 2

       revenue, by operating segment, for the periods presented. Lastly, please
describe to us
       any other disaggregated revenue information regularly reviewed by the
CODM, not
       otherwise referenced in the response, and provide us an example of this
information
       from 2024.
       Please contact Michael Fay at 202-551-3812 or Li Xiao at 202-551-4391 if
you have
questions regarding comments on the financial statements and related matters.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of
Industrial Applications and
                                                            Services