July 24, 2019

John A. Haudrich
Chief Financial Officer
OWENS ILLINOIS INC /DE/
One Michael Owens Way
Perrysburg, Ohio 43551

       Re: OWENS ILLINOIS INC /DE/
           Form 10-K For the Year Ended December 31, 2018
           Filed February 14, 2019
           File No. 001-09576

Dear Mr. Haudrich:

       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 10-K For the Year Ended December 31, 2018

Item 1A. Risk Factors
Asbestos-Related Liability, page 8

1.    We note from your disclosure on page 89 that you recorded a material
adjustment to your
      asbestos-related liabilities during the fourth quarter of 2018 in light
of additional
      information you obtained about higher estimated future claim volumes and
values, due to
      factors including changes in the law, procedure, the expansion of
judicial resources in
      certain jurisdictions, and renewed attention to dockets of
non-mesothelioma cases. Please
      tell us how you considered expanding your risk factor disclosure to more
fully address and
      discuss the factors impacting the increased likelihood of additional
losses and whether you
      expect these factors to continue to impact your financial condition and
operating
      results. Please also tell us how you considered expanding your annual and
quarterly
      MD&A disclosures to more fully disclose and discuss the following:
        the specific changes in the law, procedure, the expansion of judicial
resources in
 John A. Haudrich
OWENS ILLINOIS INC /DE/
July 24, 2019
Page 2
             certain jurisdictions, and renewed attention to dockets of
non-mesothelioma cases that
             resulted in higher estimated future claim volumes and values;
             the specific events and circumstances that occurred or you became
aware of during the
             fourth quarter of 2018 that resulted in the additional charge you
recorded;
             how you determined the amount of the additional charge you
recorded, including the
             specific changes in assumptions that impacted your
asbestos-related liability; and
             updated claims activity roll-forwards in your Form 10-Qs,
especially in light of the
             apparent change in your claims strategy.


        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 SiSi Cheng at 202-551-5004 or Anne McConnell at
202-551-3709
if you have any questions.



                                                              Sincerely,
FirstName LastNameJohn A. Haudrich
                                                              Division of
Corporation Finance
Comapany NameOWENS ILLINOIS INC /DE/
                                                              Office of
Manufacturing and
July 24, 2019 Page 2                                          Construction
FirstName LastName