SecProbe.io

July 14, 2015

Via E -mail
Mr. Stephen M. Bunker
Executive Vice President, Chief Financial  Officer , and Treasurer
Nature’s Sunshine Products,  Inc.
2500 West Executive Parkway, Suite  100
Lehi, Utah 84043

Re: Nature’s Sunshine Products , Inc.
  Form 10 -K for Fiscal Year Ended December 31, 201 4
  Filed March 13 , 201 5
File No. 1 -34483

Dear Mr. Bunker :

We have limited our review to only your financial statements and related disclosures .  In
our comment , we ask you to provide us with information so we may better understand your
disclosure.

Please respond to this letter within 10 business days by providing the requested
information or by advising us when you will provide the requested re sponse.  If you do not
believe the  comment applies to your facts and circumstances, please tell us  why in your
response.  Please furnish us a letter on EDGAR under the form type label CORRESP that keys
your response to our comment .

After reviewing the information provided, we may raise additional comments and/or
request that you amend your filing.

Notes to Consolidated Financial Statements
Note 10. Income Taxes, page 67

1. Please help us understand the nature of the changes in the effective tax rate from 31.0
percent for  2013 to (3.9) percent for 2014 . In this regard, please:
 Explain to us why the foreign tax credit line item of the components of U.S. tax
impact of foreign operations increased significantly relative to the d ividends received
from foreign subsidiaries line item  in 2014 .
 Provide us your computation of the 48.8% impact of the valuation  allowance change
in the 2014 effective tax rate reconciliation and explain why it does not appear to be
reasonable in relation to the change in the valuation allowance.
 Provide us your computation of the 8.8% impact of unrecognized tax benefits in the
2014 effective tax rate reconciliation and explain why it does not appear to be

Mr. Stephen M. Bunker
Nature’s Sunshine Products , Inc.
July 14, 2015
Page 2

 reasonable in relation to the activity in the reconciliation of the beginning and ending
amount of liabilities associated with uncertain tax benefits  for 2014 .

We urge all persons who are responsible for the accuracy and a dequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its m anagement are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

In responding to our comment , please provide  a written statement from the company
acknowle dging that:
 the company is responsible for the adequacy and accuracy of the disclosure in the
filing;
 staff comments or changes to disclosure in response to staff comments do not
foreclose the Commission from taking any  action with respect to this  filing; and
 the company may not assert staff comments as a defense in any proceeding initiated
by the Commission or any person under the federal securities laws of the United
States.

You may c ontact Mary Mast , Senior Staff Accountant, at (202) 551 -3613  if you hav e
questions regarding the comments.  In this regard, do not hesitate to contact me at (202) 551 -
3679.

Sincerely,

 /s/ Jim B. Rosenberg

Jim B. Rosenberg
Senior Assistant Chief Accountant