November 27, 2018

David Yawman
Executive Vice President, Government Affairs, General Counsel
PepsiCo, Inc.
700 Anderson Hill Road
Purchase, NY 10577

       Re: PepsiCo, Inc.
           Registration Statement on Form S-4
           Filed November 19, 2018
           File No. 333-228466

Dear Mr. Yawman:

       This is to advise you that we have not reviewed and will not review your
registration
statement.

        Please refer to Rules 460 and 461 regarding requests for acceleration.
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.

       Please contact Ronald E. Alper at 202-551-3329 with any questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of
Beverages, Apparel and
                                                            Mining
cc:    Joseph A. Hall