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United States securities and exchange commission logo
April 8, 2021
Christian Hanke
Chief Financial Officer
Oatly Group AB
Stora Varvsgatan 6a
211 19 Malm
Sweden
Re: Oatly Group AB
Amendment No. 1 to
Draft Registration
Statement on Form F-1
Submitted March 25,
2021
CIK No. 0001843586
Dear Mr. Hanke:
We have reviewed your amended draft registration statement 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 this letter by providing the requested
information and either submitting
an amended draft registration statement or publicly filing your
registration statement on
EDGAR. If you do not believe our comments apply to your facts and
circumstances or do not
believe an amendment is appropriate, please tell us why in your
response.
After reviewing the information you provide in response to these
comments and your
amended draft registration statement or filed registration statement, we
may have additional
comments.
Amendment No. 1 to Confidential Draft Registration Statement on Form F-1
submitted March
25, 2021
Summary, page 1
1. We note your disclosure
in footnote 1 on page 121 that CR Holdings is indirectly and
wholly owned by China
Resources Company Limited and that the State-owned Assets
Supervision and
Administration Commission of the State Council of the People s
Republic of China
performs the duty of investor of China Resources Company Limited on
behalf of the State
Council. Please revise your disclosures on pages 18 and 50 to reflect
the PRC's indirect
ownership interest in your company.
Christian Hanke
Oatly Group AB
April 8, 2021
Page 2
Liquidity and Capital Resources, page 77
2. Your disclosures indicate that in spring 2021, you will open your second
U.S. facility and
that three additional facilities in Singapore, Maanshan, China and
Peterborough, the
United Kingdom are currently under construction or in the planning
stages. Given that
these appear to be material expenditures, please revise your disclosure
to discuss the
estimated cost and time frame of these projects and how you plan to
finance them.
Additional Listing Agreement, page 122
3. We note your response to prior comment 7. Please revise to address the
first sentence of
that comment.
Consolidated Statement of Operations, page F-3
4. Please relocate the subtotal line from below gross profit to above gross
profit to ensure it
is clear that gross profit is the net of revenue and cost of goods sold.
Notes to the Consolidated Financial Statements
33. Events after the end of the reporting period, page F-50
5. Please revise your filing to disclose the date when the financial
statements were
authorized for issue and who gave that authorization. Refer to paragraph
17 of IAS 10.
You may contact Mindy Hooker at (202) 551-3732 or John Cash, Accounting
Branch
Chief, at (202) 551-3768 if you have questions regarding comments on the
financial statements
and related matters. Please contact Geoff Kruczek at (202) 551-3641 or Asia
Timmons-Pierce at
(202) 551-3754 with any other questions.
Sincerely,
FirstName LastNameChristian Hanke
Division of
Corporation Finance
Comapany NameOatly Group AB
Office of
Manufacturing
April 8, 2021 Page 2
cc: Marc Jaffe
FirstName LastName