United States securities and exchange commission logo March 10, 2022 Carol Tom Chief Executive Officer UNITED PARCEL SERVICE INC 55 Glenlake Parkway, N.E Atlanta, Georgia 30328 Re: UNITED PARCEL SERVICE INC Form 10-K for Fiscal Year Ended December 31, 2021 Filed February 22, 2022 File No. 001-15451 Dear Ms. Tom : We have limited our review of your filing to the financial statements and related disclosures and have the following comment. 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 comment 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 comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Form 10-K for Fiscal Year Ended December 31, 2021 Item 1A. Risk Factors Changes in general economic conditions, in the U.S. and internationally, may adversely affect us., page 9 1. You refer to the adverse impact on your business due to geopolitical uncertainties and conflicts in the Russian Federation and Ukraine. Please describe the adverse impact of Russia s invasion of the Ukraine on your business, including the impact on your operations and potential asset impairments. Carol Tom UNITED PARCEL SERVICE INC March 10, 2022 Page 2 In closing, 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 Sondra Snyder, Staff Accountant at (202) 551-3332 or Gus Rodriguez, Accounting Branch Chief at (202) 551-3752 with any questions. FirstName LastNameCarol Tom Sincerely, Comapany NameUNITED PARCEL SERVICE INC Division of Corporation Finance March 10, 2022 Page 2 Office of Energy & Transportation FirstName LastName