Exhibit 8.1
May 19, 2016
3M Company
 3M Center
 St. Paul, Minnesota 55144-1000
Re:     3M Company
  Medium-Term Notes, Series F
In connection with the Prospectus Supplement dated May 19, 2016 (the Prospectus Supplement) to the Prospectus dated May 16, 2014 of 3M Company, a Delaware corporation (the Company), relating to the offer of up to $18,000,000,000 aggregate principal amount of the Companys Medium-Term Notes, Series F, I hereby consent to the use of my name and confirm to you my opinion as set forth under Certain U.S. Federal Income Tax Considerations in the Prospectus Supplement.
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 Very truly yours,  |    
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 /s/ Christina Spence  |    
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 Christina Spence  |    
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 Director, Tax Planning  |