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 B&G Foods, Inc.
 Four Gatehall Drive
 Parsippany, NJ 07054
 Tel: (973) 401-6500
 Fax: (973) 630-6550

 Via Edgar

 July 23, 2025

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 Office of Manufacturing

 100 F. Street, N.E.

 Washington, DC 20549

 Attn: 
 Mr. Ernest Greene, Senior Accountant

 Ms. Anne McConnell, Senior Accountant

 Re: 
 B&G Foods, Inc.

 Form 10-K for the Year Ended December 28, 2024

 Filed February 25, 2025

 File No. 001-32316

 Ladies and Gentlemen:

 This letter is submitted on behalf of B&G Foods, Inc. (the
 " Company " or " our company "), in response to the comments that you have provided on behalf of the
staff of the Division of Corporation Finance (the " Staff ") of the U.S. Securities and Exchange Commission (the " SEC ")
in your letter dated July 9, 2025 (the " Comment Letter ").

 We have reviewed your comments carefully and set forth our responses
below. For your convenience, we have included above each response a copy in italics of the comment to which we are responding.

 Comments and Responses :

 Form 10-K for the Year Ended December 28, 2024

 Management's Discussion and Analysis of Financial Condition and
Results of Operations

 Critical Accounting Policies; Use of Estimates

 Goodwill and Other Intangible Assets, page 37

 1. We have read your response to prior comment one. We note you plan to disclose the range of calculated fair values over book values
for your indefinite-lived intangible assets and identify and disclose brands you consider at higher risk of impairment. For brands you
consider to be at higher risk of impairment, please confirm you will also disclose and discuss the key assumptions used to estimate their
fair values and the potential events or circumstances that could reasonable be expected to negatively those key assumptions.

 Response : We confirm that in future filings for brands
that we consider to be at higher risk of impairment, we will also disclose and discuss the key assumptions used to estimate their fair
values and the potential events or circumstances that could reasonably be expected to negatively impact those key assumptions.

 Quality Foods Since
1889

 Securities and Exchange Commission

 July 23, 2025

 Page 2

 2. We have read your response to prior comment five. Given the materiality of goodwill and intangible assets to your total assets
and equity and your disclosure that sales strategies and promotional marketing spending are centered on individual brands, we continue
to believe that disclosing net sales by material brand is meaningful and useful. We note your disclosures on page 38 of the book
values of indefinite-lived trademarks for each brand whose net sales equaled or exceeded 3% of fiscal 2024 and fiscal 2023 net sales and
for "all other brands" in aggregate; however, without also disclosing net sales by material brand, it is not clear to us how
an investor would be able to assess the potential exposure and impairment risk related to these assets. Please provide such disclosures
in MD&A in future filings.

 Response : We agree with the Staff's suggestion
that disclosing net sales by brand would enhance the meaningfulness of our current practice of reporting in MD&A the book values of
indefinite-lived trademarks for each brand whose net sales equaled or exceeded 3% of our net sales. Accordingly, we plan to include in
MD&A in future filings disclosures of net sales by brand for each brand whose net sales equaled or exceeded 3% of our net sales. These
disclosures will be similar to the individual brand net sales disclosures that had previously appeared in our financial statement footnotes
prior to our transition to four reportable segments.

 Consolidated Financial Statements

 (3) Acquisitions and Divestitures

 Divestiture of Green Giant U.S. Shelf-Stable Product Line, page 69

 3 . We have read your response to prior comment two. Please address the following:

 · Revise future filings to clarify how trademarks were allocated to assets
held for sale; and

 Response : We confirm that we will revise future filings
to clarify how trademarks were allocated to assets held for sale.

 · You state immediately prior to the sale, the realizable value of inventory
exceeded the cost, as the inventory remained saleable in the ordinary course of business; however, after the broader group of assets was
characterized as assets held for sale, the inventory lost its individual character and its impairment was recorded as part of an impairment
of the group of assets held for sale. More fully explain to us what "the inventory lost its individual character" means and
address why the inventory would not remain saleable at realizable value after the transfer to assets held for sale. Also, explain how
you considered the guidance in ASC 420-10-S99-3 in recording the related loss.

 Response : In connection with the sale of the Green
Giant U.S. shelf-stable product line, our company classified the related assets as held for sale in accordance with ASC 360-10-45-9.
Consistent with the prescribed ordering of impairment testing for assets held for sale, we first evaluated assets outside the scope of
ASC 360, including inventory under ASC 330, and concluded that no impairment was required under ASC 330, as the realizable value of the
inventory exceeded its carrying amount. Upon this classification, we evaluated the disposal group as a single unit of account for impairment
purposes, consistent with the guidance in ASC 360-10-35-38 through 35-43. As a result, we determined that the individual assets within
the disposal group, including inventory, no longer represent separate units of account for measurement purposes. The disposal group was
assessed as a whole, and the impairment was measured by comparing the carrying amount of the group to its fair value less costs to sell.

 Securities and Exchange Commission

 July 23, 2025

 Page 3

 When we stated that the "inventory lost its individual
character," we meant that the inventory was no longer evaluated for impairment on a standalone basis under ASC 330 but instead became
part of the disposal group subject to ASC 360. Although the inventory remained saleable in the ordinary course of business, the fair value
of the entire disposal group less the costs to sell the disposal group was below the carrying amount of the disposal group, and the resulting
impairment was allocated to the disposal group as a whole in accordance with ASC 360-10-35-41.

 This approach is consistent with the interpretive guidance
discussed in the Staff speech by Adam Brown at the 2008 AICPA National Conference on Current SEC and PCAOB Developments. In that speech,
Mr. Brown stated that there are two acceptable views under Statement 144 (now codified in ASC 360), one of which permits the redefinition
of the unit of account to the disposal group level, thereby allowing impairment to be allocated across all assets in the group, including
inventory and receivables. We followed this view because the impairment recognized exceeded the carrying amount of the long-lived assets
in the disposal group. Had we followed the alternative view described in the speech and limited the impairment to the carrying amount
of the long-lived assets, the impairment loss would have been smaller, and the remaining loss would have been recognized as part of the
loss on disposal at the time of sale. We believe our approach better reflects the substance of the transaction and provides more timely
recognition of the economic loss.

 We also considered the guidance in ASC 420-10-S99-3, which
addresses the recognition of losses related to exit or disposal activities. We concluded that this guidance was not applicable to our
fact pattern, as ASC 420-10-S99-3 relates specifically to inventory markdowns, whereas the loss we recognized was a write-down of a disposal
group under ASC 360. The impairment was not the result of inventory markdowns relating to a plan to exit a business activity, but rather
a single strategic disposal transaction of a non-core product line.

 Consistent with ASC 360-10-45-4 and 45-5, the impairment
loss was presented as a single net amount within income from continuing operations. We will revise future filings, as applicable, to clarify
our accounting treatment and the rationale for how an impairment was measured and allocated to the disposal group, including inventory.

 If you have any questions or desire further information regarding the
Company's responses, please contact me at (973) 867-5066.

 Sincerely,

 /s/ Bruce C. Wacha

 Bruce C. Wacha

 Executive Vice President of Finance and Chief Financial Officer

 cc: 
 Scott E. Lerner, Executive Vice President, General Counsel and Secretary

 Michael D. Adasczik, Vice President of Finance and Chief Accounting Officer