Re:	Colgate-Palmolive Company Form 10-K for the Year Ended December 31, 2012 and Definitive Proxy Statement on Schedule 14A (File No. 1-644)

1.	Where a comment below requests additional disclosures or other revisions to be made, these revisions should be included in your future filings, including your interim filings, if applicable.

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2.	We note that during your fourth quarter and fiscal year-end 2012 earnings conference call held on January 31, 2013, you indicated that the Venezuelan devaluation would have an

•	Provide disaggregated financial information including a summarized balance sheet, income statements, and cash flow statements for your Venezuelan operations;

•	Describe all likely implications of the devaluation, from both an accounting and operational standpoint;

•	Discuss any changes in profitability related to the increase in the cost of imports and in- country sales prices of imported goods due to the devaluation;

•	Discuss any government pressures on vendors not to change sales prices and the expected effect on profitability after the devaluation;

•	Describe any business practices or policies that have changed or are expected to change as a result of the devaluation; and

•	If applicable, explain and quantify where possible the effect of the devaluation on your compliance with any debt covenants.

•	Provide disaggregated financial information including a summarized balance sheet, income statements, and cash flow statements for your Venezuelan operations;

•	The materiality of our Venezuelan operations relative to our global business;

•	The information an investor would need to understand the operating environment in Venezuela, taking into consideration questions from the investor community; and

•	The information an investor would need to understand the one-time and ongoing impact of the recent and potential future devaluations of the Venezuelan currency.

•	The percentage of consolidated Net sales we expect CP Venezuela to represent in 2013 following the February 2013 devaluation;

•	Estimates of the one-time and ongoing impacts as a result of the February 2013 devaluation of the Venezuelan currency;

•	CP Venezuela's local currency-denominated net monetary asset position as of December 31, 2012 and following the February 2013 devaluation;

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•	The amount of cash in Venezuela subject to exchange controls in the context of consolidated worldwide cash and cash held by the Company's foreign subsidiaries; and

•	The amount of U.S. dollar-linked, devaluation-protected bonds and the amount of Bolivar fuerte-denominated, fixed interest rate bonds that CP Venezuela held as of December 31, 2012.

•	Describe all likely implications of the devaluation, from both an accounting and operational standpoint;

•	Discuss any changes in profitability related to the increase in the cost of imports and in-country sales prices of imported goods due to the devaluation;

•	Discuss any government pressures on vendors not to change sales prices and the expected effect on profitability after the devaluation;

•	Describe any business practices or policies that have changed or are expected to change as a result of the devaluation; and

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•	If applicable, explain and quantify where possible the effect of the devaluation on your compliance with any debt covenants.

3.

We note that during your fourth quarter and fiscal year-end 2012 earnings conference call held on January 31, 2013, you provided detailed discussions regarding both significant product launches by segment and regional market share by product category. Since it appears that both of these items are important to the manner in which management views and analyzes the business, we believe that your MD&A may benefit in future filings from similar disclosures. For example, we note that in your earnings call transcripts you have mentioned that in the U.S. the fastest-growing segment is Natural's, a segment consisting of dozens of brands where you are under-represented. Your launch of Hill's Science Diet Ideal Balance in 2011 was an initiative to address this situation. We also note the discussion in your earnings calls and earnings release mentioning your strategy of re-launching Science Diet and introducing new products. Please show us in your supplemental response what your future filing revisions will look like.

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4.

As a related matter, please revise to explain the reasons behind significant fluctuations in each of your various income statement line items. For example, you mention on page 23 that volume growth and net selling prices increased during 2012 in both North American and Latin America while net selling prices decreased in Europe/South Pacific during 2011 and 2012. In is unclear what factors were driving the volume growth and changes in selling prices both overall and in each segment. To the extent there were multiple factors, please separately quantify the impact of each factor and discuss in greater detail the reason(s) for each change. For example, if the volume growth was attributable to new product launches, please identify and quantify the launches which had the greatest impact upon your results. Please show us in your supplemental response what your future filing revisions will look like.

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5.

We note that in your discussion of Hill's Pet Nutrition in your fourth quarter earnings call transcript you indicated that the Science Diet formulation will contain 100% natural ingredients with quality animal proteins and no by-products. We note that these ingredients generally cost substantially more than those ingredients (e.g. cornmeal and soy) included in the prior formulation. In your fourth quarter earnings call transcript you indicated that you do not intend to increase the price or change package sizing to offset these increased costs. In future filings, please disclose the impact the increased costs will have on net sales, revenues and income, if material. Please refer to Item 303 of Regulation S-K and SEC Release 33-8350.

6.	We note that there have been volume declines for Hill's Pet Nutrition in the U.S., Japan and Europe over the past three years. In future filings, please expand your disclosure to address this trend, if material.

7.

You disclose on page 78 that the operations of your Oral, Personal and Home Care segment are managed geographically in four reportable operating segments. So that we may more clearly understand your segment reporting, please tell us supplementally each of your operating segments and, if applicable, explain to us how you met each of the criteria in ASC 280-10-50-11 in aggregating two or more operating segments into the same reportable segment.

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1.	The nature of the products and services;

2.	The nature of the production processes;

3.	The type or class of customer for their products and services;

4.	The methods used to distribute their products or provide their services; and

5.	The nature of the regulatory environment.

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8.

We note that you have identified the Currency Neutral Earnings Per Share goal upon which you based cash awards in 2012 ($5.38). We also note that executives were given an "assigned bonus award opportunity", expressed as a percentage of salary, and that payouts could range from zero, if performance fell below a "threshold level" to a maximum of some multiple of the assigned award opportunity for each officer. In future filings, please clarify what earnings per share or other goal amounts were necessary to meet threshold, target and maximum payout levels. For example, it appears that the officers received the maximum payout with respect to the

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9.

We note your disclosure that the P&O Committee granted stock options and restricted stock awards to named executive officers to recognize their contributions and ensure their continued service. In future filings, please elaborate on the nature of each officer's specific contributions and achievements to give better context for demonstrating the basis for the Committee's specific compensation decisions. Although quantitative targets for subjective or qualitative assessments may not be required, you should provide insight into how qualitative inputs are translated into objective pay determinations. See Item 402(b)(2)(vii) of Regulation S-K. Please also provide us supplementally with a draft of what your disclosure would have looked like for 2012.

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10.

We note your disclosure on page 31 that cash bonuses payouts range from zero, if performance falls below a threshold level, to a maximum of two times for Mr. Cook and Mr. Skala and 1.5 times for the other named executive officers. In future filings, please disclose the amounts payable at the threshold level in the threshold column under Estimated Possible Payouts Under Non-Equity Incentive Plan Awards section of the Grant of Plan-Based Awards table.

11.	It appears that Mrs. Hancock's charitable contribution amount exceeds the $8,000 program limit described in footnote 4. Please explain and revise in future filings to the extent appropriate.

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•	The Company is responsible for the adequacy and accuracy of the disclosure in its filings;

•	Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the filing; and

•	The Company may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.