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SEC Comment Letter for HAWKINS (HWKN) — Feb 27, 2026

HAWKINS INC
Date: Feb. 27, 2026 · CIK: 0000046250 · Accession: 0000000000-26-002051

Financial Reporting Internal Controls Regulatory Compliance

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File numbers found in text: 000-07647

Date
February 27, 2026
Author
Division of
Form
UPLOAD
Company
HAWKINS INC

Letter

Re: Hawkins, Inc. Form 10-K for Fiscal Year Ended March 30, 2025 Form 8-K Furnished January 28, 2026 File No. 000-07647 Dear Jeffrey Oldenkamp:

February 27, 2026

Jeffrey Oldenkamp Executive Vice President and Chief Financial Officer Hawkins, Inc. 2381 Rosegate Roseville, MN 55113

We have limited our review of your filing to the financial statements and related disclosures and have the following comment(s).

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 Fiscal Year Ended March 30, 2025 Notes to Consolidated Financial Statements, page 32

1. It appears selling, general and administrative expenses is material to your results of operations. Please consider describing what this line item consists of. Note 14 - Leases, page 45

2. Please disclose the cash paid for amounts included in the measurement of lease liabilities pursuant to ASC 842-20-50-4.g.1. Note 15 - Segment Information, page 45

3. You disclose here there are no intersegment sales. On page 1 under Business you disclose the Industrial Group ("Industrial") repackages water treatment chemicals for the Water Treatment Group ("Water Treatment"), there are significant synergies between Water Treatment and Industrial regarding chemicals sold by Water Treatment derived from large volume of chemicals purchased by Industrial, and Water Treatment and Industrial share certain resources. In view of this, please describe for us and disclose as February 27, 2026 Page 2

appropriate the relationship between these two groups such that no intersegment sales occur. Also, describe for us and disclose as appropriate how the costs of resources shared between these groups and chemicals purchased by Industrial on behalf of Water Treatment are assigned to the appropriate segment. Form 8-K Furnished January 28, 2026 Exhibit 99.1, page 1

4. Under the caption "Third Quarter Fiscal Year 2026 Highlights," for the non-GAAP measure Adjusted EBITDA, please present the most directly comparable GAAP measure of net income with equal or greater prominence. Refer to Question 102.10(a) of the Compliance and 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 Robert Shapiro at 202-551-3273 or Doug Jones at 202-551-3309 with any questions.

Sincerely,
Division of
Corporation Finance
Office of Trade &
Services

Show Raw Text
<DOCUMENT>
<TYPE>TEXT-EXTRACT
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<TEXT>
 February 27, 2026

Jeffrey Oldenkamp
Executive Vice President and Chief Financial Officer
Hawkins, Inc.
2381 Rosegate
Roseville, MN 55113

 Re: Hawkins, Inc.
 Form 10-K for Fiscal Year Ended March 30, 2025
 Form 8-K Furnished January 28, 2026
 File No. 000-07647
Dear Jeffrey Oldenkamp:

 We have limited our review of your filing to the financial statements
and related
disclosures and have the following comment(s).

 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 Fiscal Year Ended March 30, 2025
Notes to Consolidated Financial Statements, page 32

1. It appears selling, general and administrative expenses is material to
your results of
 operations. Please consider describing what this line item consists of.
Note 14 - Leases, page 45

2. Please disclose the cash paid for amounts included in the measurement of
lease liabilities
 pursuant to ASC 842-20-50-4.g.1.
Note 15 - Segment Information, page 45

3. You disclose here there are no intersegment sales. On page 1 under
Business you
 disclose the Industrial Group ("Industrial") repackages water treatment
chemicals for
 the Water Treatment Group ("Water Treatment"), there are significant
synergies between
 Water Treatment and Industrial regarding chemicals sold by Water
Treatment derived
 from large volume of chemicals purchased by Industrial, and Water
Treatment and
 Industrial share certain resources. In view of this, please describe for
us and disclose as
 February 27, 2026
Page 2

 appropriate the relationship between these two groups such that no
intersegment sales
 occur. Also, describe for us and disclose as appropriate how the costs
of resources shared
 between these groups and chemicals purchased by Industrial on behalf of
Water
 Treatment are assigned to the appropriate segment.
Form 8-K Furnished January 28, 2026
Exhibit 99.1, page 1

4. Under the caption "Third Quarter Fiscal Year 2026 Highlights," for the
non-GAAP
 measure Adjusted EBITDA, please present the most directly comparable
GAAP measure
 of net income with equal or greater prominence. Refer to Question
102.10(a) of the
 Compliance and 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 Robert Shapiro at 202-551-3273 or Doug Jones at
202-551-3309 with any
questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Trade &
Services
</TEXT>
</DOCUMENT>