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February 14, 2023
Timothy Lain
Chief Financial Officer
Carpenter Technology Corp.
1735 Market Street, 15th Floor
Philadelphia, PA 19103
Re:Carpenter Technology Corp.
Form 10-K for the Fiscal Year Ended June 30, 2022
Filed August 15, 2022
File No. 001-05828
Dear Timothy Lain:
            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 Fiscal Year Ended June 30, 2022
Management's Discussion and Analysis of Financial Condition and Results of Operations, page
19
1.Please revise MD&A in future annual and quarterly filings to more fully address the
following:

•You disclose that results for fiscal year 2022 were negatively impacted by certain
challenges, including supply chain disruptions. Please discuss whether and how
supply chain disruptions materially affect your outlook or business goals. Quantify
and disclose, to the extent possible, how sales, profits, and/or liquidity have been
impacted and discuss known trends or uncertainties resulting from mitigation efforts
undertaken, including whether any mitigation efforts introduce new material risks,
including those related to product quality, reliability, or approval.

 FirstName LastNameTimothy Lain
 Comapany NameCarpenter Technology Corp.
 February 14, 2023 Page 2
 FirstName LastName
Timothy Lain
Carpenter Technology Corp.
February 14, 2023
Page 2
•You disclose here, and in quarterly filings, that you are experiencing ongoing
inflationary cost increases. Please quantify and disclose the impact of the inflationary
pressures you experience, including the combined impact of inflation and your LIFO
inventory valuation method on cost of sales, gross profit, and inventory. Expand your
disclosures to also indicate the extent to which you are able to pass increased costs on
to customers, through surcharges, to mitigate inflationary pressures.
Non-GAAP Financial Measures, page 37
2.We note you present several non-GAAP performance measures in which you eliminate
the LIFO decrement charge you recorded in FY 2021. Please more fully explain to us
what the LIFO decrement charge represents and why you believe eliminating it from non-
GAAP performance measures is appropriate given your use of LIFO to account for the
majority of your inventory. Please also specifically address the following:

•More fully explain to us how you determined the amount of the LIFO decrement
charge and the factors that resulted in the charge. In this regard, we noted disclosures
in current and prior year financial statements that indicate the current costs of LIFO
valued inventories would be substantially higher which seems to indicate a
potentially lower cost basis in older inventory balances; and

•More fully explain to us how you considered the guidance in Question 100.04 of the
Division of Corporation Finance’s Compliance & Disclosure Interpretations on Non-
GAAP Financial Measures in determining the non-GAAP performance measures you
present are appropriate.
Free Cash Flow, page 39
3.We note your calculation of the non-GAAP liquidity measure you identify as "free cash
flow" appears to differ from the standard calculation of this measure (i.e., cash flows from
operations less capital expenditures). In order to avoid potential confusion, please revise
the title of your non-GAAP liquidity measure in future filings to “adjusted free cash flow”
or something similar. Refer to Question 102.07 of the Division of Corporation Finance’s
Compliance & Disclosure Interpretations on Non-GAAP Financial Measures.
Consolidated Financial Statements
4. Revenue, page 63
4.Please revise future filings to provide the disclosures required by ASC 606-10-50-6 and
50-8 or explain why you do not believe they are required.

 FirstName LastNameTimothy Lain
 Comapany NameCarpenter Technology Corp.
 February 14, 2023 Page 3
 FirstName LastName
Timothy Lain
Carpenter Technology Corp.
February 14, 2023
Page 3
            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 Dale Welcome at 202-551-3865 or Anne McConnell at 202-551-3709
with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing