September 9, 2024

Mark Erceg
Chief Financial Officer
Newell Brands Inc.
6655 Peachtree Dunwoody Road
Atlanta, GA 30328

       Re: Newell Brands Inc.
           Form 10-K for the Fiscal Year Ended December 31, 2023
           Filed February 21, 2024
           Form 8-K dated February 9, 2024
           File No. 001-09608
Dear Mark Erceg:

       We have limited our review of your filings to the financial statements
and related
disclosures and have the following comments.

       Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this letter, we may have additional
comments.

Form 10-K for the Fiscal Year Ended December 31, 2023
Item 7. Mangement's Discussion and Analysis of Financial Condition and Results
of Operations
Results of Operations, Consolidated Operating Results 2023 vs. 2022, page 29

1.     In your discussion of net sales and gross profit, you cite multiple
factors as impacting
       your results of operations but provide no quantification of the
contribution of each factor
       to the material changes nor do you provide any context for the
underlying reasons for
       such changes. Where one or more factors contributed to a material change
in a line item,
       please revise future filings to describe the underlying reasons for
these changes in
       quantitative and qualitative terms. We refer to guidance in Item 303(b)
of Regulation S-K.
 September 9, 2024
Page 2
Form 8-K dated February 9, 2024
Exhibit 99.1
Reconciliation of GAAP and Non-GAAP Information (Unaudited), page 13

2.     We note your non-GAAP reconciliations appear to include a full non-GAAP
income
       statement. The presentation of a full non-GAAP income statement, or a
presentation that
       gives the appearance of one, may place undue prominence on the non-GAAP
information
       and give the impression that the non-GAAP income statement represents a
comprehensive
       basis of accounting. Please remove this presentation in your future
filings. To the extent
       you wish to present any of the non-GAAP measures, you should present a
separate
       reconciliation for each non-GAAP measure and provide all the disclosures
required by
       Item 10(e)(1)(i) of Regulation S-K including quantification and
description of each
       adjustment individually. Refer to Question 102.10(a) and (c) of the
C&DIs for Non-
       GAAP Financial Measures.
3.     In future filings, please include a separate footnote for each non-GAAP
adjustment that
       describes in further detail the adjustment, the related facts and
circumstances and the
       reason why the adjustment is included. Please provide us any proposed
disclosure.
4.     We note certain non-GAAP adjustments for 2023 and 2022 include bad debt
reserve
       related to an international customer, expenses for certain legal
proceedings, and inventory
       reserve due to changes in raw material regulation. Please describe these
adjustments to us
       in further detail and tell us how you considered the guidance in
Question 100.01 of the
       C&DIs for Non-GAAP Financial Measures.
5.     Please tell us and revise future filings to detail the nature and
composition of the non-
       GAAP adjustment to cost of products sold and selling, general and
administrative
       expenses for "restructuring-related" costs. In your response, please
tell us how you
       considered Question 100.01 of the Division of Corporation Finance's
Compliance
       & Disclosure Interpretations on Non-GAAP Financial Measures.

       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.

       Please contact Michael Fay at 202-551-3812 or Kristin Lochhead at
202-551-3664 with
any questions.



                                                             Sincerely,

                                                             Division of
Corporation Finance
                                                             Office of
Industrial Applications and
                                                             Services