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CORRESP

 September 7, 2022

VIA EDGAR CORRESPONDENCE FILE

 United States
Securities and Exchange Commission

 Division of Corporation Finance

100 F. Street, N.E.

 Washington, D.C. 20549

Re:
 Leggett & Platt, Incorporated

 Form 10-K for Fiscal Year Ended December 31, 2021

 Filed February 22, 2022

 File No. 001-07845

We are writing in response to the Staff’s comment letter dated August 25, 2022, with respect to the above referenced file. In order to facilitate
your review, our letter presents the Staff’s comment followed by our response.

 Form 10-K for Fiscal
Year Ended December 31, 2021

 General

1. We note that you provided more expansive disclosure in your 2022 Sustainability Report than you provided in your SEC filings. Please advise us what
consideration you gave to providing the same type of climate-related disclosure in your SEC filings as you provided in your 2022 Sustainability Report.

RESPONSE:

 When considering whether to
include climate-related disclosure in our filings with the Securities and Exchange Commission (SEC), the Company takes into account applicable SEC rules and regulations, including Item 101, Item 103, Item 105 and
Item 303 of Regulation S-K, as well as available guidance from the Staff (including the SEC’s 2010 “Commission Guidance Regarding Disclosure Related
to Climate Change” and the SEC’s 2021 “Sample Letter to Companies Regarding Climate Change Disclosures”) and applicable standards of materiality. We provide disclosure in our
SEC filings to satisfy our obligations under the federal securities laws to provide “material” information to our shareholders and the investing public.

We provided supplementary climate-related disclosure in our 2022 Sustainability Report (Sustainability Report) to address evolving stakeholder expectations.
The Sustainability Report is designed to provide information regarding the Company’s ESG performance to a broad audience that includes investors, employee-partners, customers, communities, suppliers and other interested parties. As a result,
the Sustainability Report may, and indeed does, include detailed information regarding the Company’s efforts to reduce energy use and greenhouse gas (GHG) emissions. However, this information is not material under the federal securities laws
and is beyond the scope of the information required to be disclosed pursuant to applicable SEC rules and/or regulations.

 United States Securities and Exchange Commission

Division of Corporation Finance

 September 7, 2022

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 The Company’s Public Disclosure Committee (PDC) meets on a quarterly basis to ensure material
information, risks and impacts (including climate-related risks and impacts), either quantitatively or qualitatively, to the Company’s business, capital expenditures, results of operations, financial condition, prospects and competitive
position are appropriately disclosed in its SEC filings. The PDC consists of a cross-functional team including our Executive Chairman, President & CEO, CFO, Chief Accounting Officer, General Counsel,
SVP-Investor Relations, SVP-Business Support Services, and additional representatives from our accounting, legal, investor relations, tax and internal audit teams. The
PDC considers, among other things, the applicable disclosure requirements under applicable SEC rules and regulations to determine if all required information has been properly disclosed.

The PDC concluded that our Form 10-K disclosure on page 24 under Risk Factors, and on page 56 under Management’s
Discussion and Analysis of Financial Condition and Results of Operations (MD&A), contained all appropriate disclosure of material risks and impacts to the Company regarding climate change in accordance with the above referenced SEC rules and
guidance. The PDC reached this conclusion, in part, by evaluating the subject matter, depth and breadth of disclosure in the Form 10-K compared to the disclosure in the Sustainability Report. The Form 10-K included the following:

•

 A risk factor titled “Climate change laws, regulations, and impacts could negatively impact the
Company’s business, capital expenditures, results of operations, financial condition, competitive position, and reputation.”

•

 The MD&A section contained disclosure regarding the lack of consistency and potential change in
climate-related laws, policies and regulation. It also contained disclosure regarding the indirect consequences of climate-related impacts, such as (i) weather-related impacts causing supply chain shortages of foam which constrained overall
mattress production and reduced the Company’s production levels, (ii) the risk of increased bad debt expense resulting from the potential negative effect on customers’ payments, and (iii) increased property insurance premiums.

•

 The MD&A section provided disclosure regarding the Company’s compliance costs related to climate-change
and the Company’s ESG strategy moving forward which includes evaluating opportunities to reduce our carbon footprint, setting goals for carbon reduction, and measuring performance in achieving those goals.

•

 The MD&A disclosure included a statement that we were working on completing our first GHG emissions
inventory, and that we did not have an estimate of capital expenditures or operating costs that may be required to implement any GHG reduction strategy.

The Sustainability Report included disclosure regarding climate risk and carbon reduction, reducing energy consumption and other energy efficiency initiatives
(fleet fuel consumption, waste management and recycling, effluent management and chemical safety, and water). The disclosure of these programs was determined to be immaterial, and to represent only granular details of the Form 10-K disclosure related to our future GHG reduction strategy. We assessed the materiality of the programs contained in the Sustainability Report that are designed to either reduce energy consumption or the
emission of GHG. These programs included the (i) deployment of LED lighting designed to reduce electricity consumption; (ii) reduction of energy consumption at our steel rod mill; and (iii) reduction of fleet fuel consumption. We
determined that for each year in the three-year period covered by the Form 10-K, these programs, in the aggregate, provided cost savings of less than 0.1% of Cost of Goods Sold. Moreover, since the GHG
emission reduction strategy was (and still is) being analyzed, and therefore has not yet been adopted, the magnitude of any future impact to our financial statements from these specific programs also has not been determined, but is not expected to
be materially different than past experience. As such, the PDC concluded that the supplementary disclosure contained in the Sustainability Report of these programs was not material and was not required to be included in the Company’s Form 10-K.

 United States Securities and Exchange Commission

Division of Corporation Finance

 September 7, 2022

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 The Company acknowledges the Staff’s comment and in future filings, as applicable, will continue to
consider disclosure in its periodic reports of additional climate-related information included in its sustainability reports, to the extent material or otherwise required. We acknowledge our obligation to continuously review these climate-related
matters as part of our ongoing disclosure controls and procedures and to disclose climate-change related matters in our SEC filings to the extent such matters are material.

Risk Factors, page 17

 2. Disclose the material
effects of transition risks related to climate change that may affect your business, financial condition, and results of operations, such as policy and regulatory changes that could impose operational and compliance burdens, market trends that may
alter business opportunities, credit risks, or technological changes.

 RESPONSE:

In response to the Staff’s comment, the Company respectfully advises the Staff that the Company considers applicable SEC disclosure rules, regulations and
Staff guidance, as referenced above, when preparing its SEC filings, and as applicable and to the extent material, evaluates (through its PDC) disclosure regarding the material effects of transition risks related to climate change.

Policy and Regulatory Changes. As part of our process and analysis, the PDC determined to include on page 24 of the Form
10-K the risk factor “Climate change laws, regulations, and impacts could negatively impact the Company’s business, capital expenditures, results of operations, financial condition, competitive
position, and reputation.” This risk factor discloses, among other things, the transition risk applicable to the Company regarding newly enacted laws or regulations that may impose significant operational restrictions and compliance
requirements on the Company, by providing:

 “Also, if these laws or regulations impose significant operational restrictions and
compliance requirements on us, they could increase costs associated with our operations, including costs for raw materials and transportation. In either event, they could negatively impact our business, capital expenditures, results of operations,
financial condition, and competitive position. Non-compliance with climate change legislative and regulatory requirements could also negatively impact our reputation.”

As part of this disclosure analysis, the Company also determined that at the time of filing the Form 10-K its business
had not been affected by, and was not reasonably likely to be affected by, material transition risks related to climate change regarding market trends that may alter business opportunities, credit risks, or technological changes. Factors considered
in the materiality analysis of each type of risk are included below.

 United States Securities and Exchange Commission

Division of Corporation Finance

 September 7, 2022

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 Market Trends that May Alter Business Opportunities. The Company manufactures products in industries
that are not significantly tied to consumer preferences or changing market demand for lower carbon footprint products. We manufacture products in three segments: (i) Bedding Products, which includes, in part, mattress innersprings, specialty
foam used primarily in bedding and furniture, private-label finished mattresses, adjustable beds, and machinery used in the bedding industry; (ii) Specialized Products, which include lumbar support and suspension systems for automotive seating,
motors, actuators and cables, aircraft tubing and hydraulic cylinders; and (iii) Furniture, Flooring & Textile Products, which include furniture components, flooring products and ground stabilization products. Most of our products are
component parts of a finished product and normally represent only a small percentage of the overall cost of the finished product, which explains why our products are not normally subject to consumer preferences regarding lower carbon footprints. We
do not have any products that directly emit GHG or are associated with exhaust systems that emit GHG.

 Regarding our automotive products, if there is a
continued or accelerated shift from gas combustion-powered automobiles to electric-powered automobiles, the automotive seating systems and other automotive components can be included in electric-powered automobiles just as they are included in gas
combustion-powered automobiles. Also, the Company is not aware that any competitive product is being offered to the marketplace on the basis that its production process generates lower GHG. As such, the Company was not (and is not) aware of any
market trend related to climate change that could reasonably likely materially affect the demand for our products, our business, financial condition or results of operations, and as of the date of this letter we have not experienced any material
impact from this transition risk.

 Credit Risks. The Company has obtained credit ratings from various credit rating agencies which assign a rating
for ESG criteria. On September 14, 2021, Fitch Ratings assigned a score to the Company regarding “GHG Emissions & Air Quality” that signified that the issue is credit neutral or has only a minimal credit impact to the
Company. On November 16, 2021, Moody’s stated “Leggett & Platt is moderately exposed to environmental, social and governance (ESG) risks.” Moody’s did not include the ESG rating in the section of its report that
identifies factors that could lead to an upgrade or downgrade of the credit rating. In February 2022, the Company received S&P’s ESG Credit Indicator Report Card which assigned the Company a neutral rating for environmental risk (which
includes climate transition risk).

 Moreover, the Company amended its $1.2 billion credit agreement and issued $500 million of public senior
notes in the fall of 2021 without any communication to the Company from market participants regarding concerns over the Company’s ESG ratings or climate change risks. Based on the Company’s external credit ratings and its historical
experience, it currently does not and did not believe, at the time of filing the Form 10-K, that it was subject to material credit risks related to climate change.

Finally, as disclosed on page 53 of the Form 10-K, the Company has not experienced material credit risks from
customers during the three years covered by the Form 10-K. Our bad debt expense was $3 million in 2019, $17 million in 2020 (impacted by COVID-19 pandemic
related declines) and $(3) million in 2021. These amounts were less than 0.4% of net trade sales for each respective year.

 Technological Changes.
The Company is not aware of any transition risk associated with technological changes related to climate change that would materially impact its manufacturing processes, business operations, product specifications, competitive position or
distribution of its products. The type of products that we manufacture (as described above) are not reasonably likely to require technological changes because of transition risks associated with climate change (i.e., our products do not directly
emit GHG emissions).

 United States Securities and Exchange Commission

Division of Corporation Finance

 September 7, 2022

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 However, technological changes could possibly be required of our manufacturing processes at some time in the
future. We are currently working on completing our first GHG inventory. Once complete, this baseline measurement will inform a long-term GHG reduction strategy, including setting reduction targets and other key areas of performance. As disclosed in
our Form 10-K on page 57, at the time of filing the Form 10-K, we did not have an estimate of the capital expenditures or operating costs that may be required to
implement our GHG reduction strategy. We were unable to arrive at an estimate primarily because the implementation of the strategy was not (and still is not) determined. However, based on quantitative materiality thresholds (determined as a
percentage of annual pre-tax income from continuing operations) the Company did not believe that any technological changes would amount to a material cost (either initially or on an ongoing basis). Through its
GHG inventory, the Company estimates over 50% of its global GHG emissions are produced at only three of its facilities (compared to roughly 130 facilities world-wide). As such, the cost to make technological changes, if required, to its production
processes to meaningfully reduce GHG emissions is not expected to be material.

 The Company will continue to monitor the effects
of transition risks related to climate change and if such risks are considered to be reasonably likely to have a material effect on its business, financial condition or results of operations, the Company will disclose such risks in future filings as
appropriate.

 3. Disclose any material litigation risks related t