United States securities and exchange commission logo November 8, 2023 Scott R. Behrens Chief Executive Officer Stepan Company 1101 Skokie Blvd., Suite 500 Northbrook, IL 60062 Re: Stepan Company Annual Report on Form 10-K for the year ended December 31, 2022 File No. 001-04462 Dear Scott R. Behrens: We have completed our review of your filing. 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. Sincerely, Division of Corporation Finance Office of Industrial Applications and Services