April 26, 2019 Dean Freeman Chief Financial Officer GCP Applied Technologies Inc. 62 Whittemore Avenue Cambridge, MA 02140-1623 Re: GCP Applied Technologies Inc. Form 10-K for Fiscal Year Ended December 21, 2018 Filed February 27, 2019 File No. 001-137533 Dear Mr. Freeman: We have limited our review of your filing to the financial statements and related disclosures 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 Management's Discussion and Analysis of Financial Condition and Results of Operations Results of Operations, page 28 1. We note you present a ratio you identify as Adjusted EBIT Return on Invested Capital that you calculate using the non-GAAP financial measure, Adjusted EBIT. However, we note you do not present this ratio using the most directly comparable GAAP measure. Please ensure all non-GAAP financial measures you present in future filings, including earnings releases filed under Form 8-K, fully comply with Item 10(e) of Regulation S-K. Dean Freeman GCP Applied Technologies Inc. April 26, 2019 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 Kevin Stertzel at (202) 551-3723 or Anne McConnell at (202) 551- 3709 with any questions. Sincerely, FirstName LastNameDean Freeman Division of Corporation Finance Comapany NameGCP Applied Technologies Inc. Office of Manufacturing and April 26, 2019 Page 2 Construction FirstName LastName