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January 25, 2023
Andrea Funk
Chief Financial Officer
EnerSys
2366 Bernville Rd.
Reading, PA 19605
Re:EnerSys
Form 10-K for the Fiscal Year Ended March 31, 2022
Filed May 25, 2022
Form 8-K Furnished November 9, 2022
File No. 001-32253
Dear Andrea Funk:
            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 March 31, 2022
Liquidity and Capital Resources
Cash Flow and Financing Activities, page 42
1.We note your presentation of "primary working capital" that is calculated as "accounts
receivable, plus inventories, minus trade accounts payable" and that excludes certain
current liabilities.  Please tell us how your presentation complies with Item 10(e)(1)(ii)(A)
of Regulation S-K, which generally prohibits excluding charges or liabilities that required
or will require cash settlement from non-GAAP liquidity measures.  Also see the
third bullet of Question 102.10(a) of the Compliance and Disclosure Interpretations on
Non-GAAP Financial Measures.

 FirstName LastNameAndrea Funk
 Comapany NameEnerSys
 January 25, 2023 Page 2
 FirstName LastName
Andrea Funk
EnerSys
January 25, 2023
Page 2
Form 8-K Furnished November 9, 2022
Exhibit 99.1 , page 1
2.When you present or discuss non-GAAP measures, please ensure that the corresponding
GAAP measures are presented or discussed with equal or greater prominence.  We note
the following items in your press release:

•An introductory bullet mentions "Adj GM" movements without a corresponding
GAAP reference.
•The table on the first page includes EBITDA and Adjusted EBITDA but not net
income.
•The "Message from the CEO" discusses adjusted gross margin and adjusted diluted
EPS without corresponding GAAP discussions.

See Item 10(e)(1)(i)(A) of Regulation S-K and Questions 102.10(a) and Question 103.01
of the Compliance and Disclosure Interpretations on Non-GAAP Financial Measures.

3.We note that you quantify a range of forward-looking adjusted diluted earnings per share
for the subsequent quarter.  To the extent available without unreasonable efforts, please
revise future filings to provide a reconciliation to the most directly comparable GAAP
measure.  If relying on the unreasonable efforts exception, please disclose  as such and
identify the information that is not available.  See Item 10(e)(1)(i)(B) of Regulation S-K
and Question 102.10(b) 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.
            You may contact Andrew Blume, Staff Accountant, at (202) 551-3254 or Melissa
Gilmore, Staff Accountant, at (202) 551-3777 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing