September 26, 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
           Response Dated September 20, 2024
           File No. 001-09608
Dear Mark Erceg:

       We have reviewed your September 20, 2024 response to our comment letter
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. Unless we
note otherwise, any references to prior comments are to comments in our
September 9, 2024
letter.

Form 8-K dated February 9, 2024
Exhibit 99.1
Reconciliation of GAAP and Non-GAAP Information (Unaudited), page 13

1.     We have reviewed your response to comment 4. Despite the circumstances
indicated in
       your response, credit losses related to customers and lower of cost or
net realizable value
       adjustments to inventory appear to represent normal, recurring operating
expenses
       necessary to operate your business as addressed in Question 100.01 of
the Compliance
       and Disclosure Interpretations for Non-GAAP Financial Measures. In this
regard, in
       future filings, please remove these components from your adjustment.
 September 26, 2024
Page 2
2.     We reference your response to comment 5 related to restructuring-related
costs. For the
       $86 million restructuring related adjustment to cost of products sold
and the $13 million
       restructuring related adjustment to selling, general and administrative
expense, please
       quantify each of the underlying adjustments indicated in your response.
Please
       also respond to the following comments to help us better understand the
nature of the
       amounts and your consideration of the guidance in Question 100.01 of the
Compliance
       and Disclosure Interpretations for Non- GAAP Financial Measures in
determining that it
       was appropriate to adjust for each of the items in the adjustment.

             Regarding the adjustment for accelerated depreciation, please
explain the nature of
           the underlying assets, whether the assets continue to be used in
operations, and when
           you intend to retire the assets;
             Explain the nature of the duplicative costs pending facility
closure or exit of business
           activity, including how you calculated the amount that is
duplicative and explain how
           you determined that these are costs to exit businesses or sites;
             Tell us the nature of the services provided by the consultants;
and
             Explain the asset valuation adjustments and disposal gains or
losses, including the
           nature of the assets, means of disposal, and when and why the assets
were impaired.
3.     As a related matter, in future filings, please quantify the individual
components of the
       restructuring and restructuring related non-GAAP adjustment, including
identifying what
       portion of the adjustment is related to restructuring costs versus
restructuring related
       costs.

       Please contact Michael Fay at 202-551-3812 or Kristin Lochhead at
202-551-3664 if you
have questions regarding comments on the financial statements and related
matters.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of
Industrial Applications and
                                                            Services