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August 24, 2022
Patrick O'Donnell
Interim Chief Financial Officer
TreeHouse Foods, Inc.
2021 Spring Road, Suite 600
Oak Brook, IL 60523
Re:TreeHouse Foods, Inc.
Form 10-K for Fiscal Year Ended December 31, 2021
Filed February 15, 2022
File No. 001-32504
Dear Mr. O'Donnell:
            We have reviewed your filing 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 Fiscal Year Ended December 31, 2021
General
1.We note that you provided more expansive disclosure in your 2021 Environmental, Social
and Governance (ESG) Report and on your website 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 2021 ESG Report
and on your website.
Risk Factors, page 11
2.Disclose any material litigation risks related to climate change and explain the potential
impact to the company.

 FirstName LastNamePatrick O'Donnell
 Comapany NameTreeHouse Foods, Inc.
 August 24, 2022 Page 2
 FirstName LastName
Patrick O'Donnell
TreeHouse Foods, Inc.
August 24, 2022
Page 2
Management's Discussion and Analysis of Financial Condition and Results of Operations, page
23
3.It appears you have identified climate-related projects in your 2021 ESG Report.  Tell us
how you considered providing disclosure regarding past capital expenditures for climate-
related projects.  Include quantitative information for the periods covered by your Form
10-K as part of your response.  In addition, the disclosure on page 36 of your Form 10-K
regarding capital expenditures for 2022 related to climate-related projects states that the
amounts “are not expected to be material individually or in the aggregate.”  Please
quantify for us the amount budgeted for 2022 and for future periods.
4.To the extent material, discuss the indirect consequences of climate-related regulation or
business trends, such as the following:
•decreased demand for goods or services that produce significant greenhouse gas
emissions or are related to carbon-based energy sources;
•increased demand for goods that result in lower emissions than competing products;
•increased competition to develop innovative new products that result in lower
emissions;
•any anticipated reputational risks resulting from operations or products that produce
material greenhouse gas emissions; and
•potential climate-related opportunities, such as the development of new products and
services and the use of lower-emission sources of energy.
5.We note your disclosure regarding the potential physical effects of climate change on
pages 13 and 18.  Please further discuss the physical effects of climate change on your
operations and results, such as weather-related damages to your property or operations,
and weather-related impacts on the cost or availability of insurance.  Include quantitative
information with your response for each of the periods covered by your Form 10-K and
explain whether increased amounts are expected in future periods.  In addition, please tell
us how you considered disclosing the potential for indirect weather-related impacts that
have affected or may affect your major customers.
6.We note your disclosure on page 19 regarding the costs of compliance with legal
requirements related to climate change.  Tell us about and quantify any compliance costs
related to climate change for the last three fiscal years and explain whether increased
amounts are expected to be incurred in future periods.
7.If material, provide disclosure about your purchase or sale of carbon credits or offsets and
any material effects on your business, financial condition, and results of operations.
Provide us with quantitative information regarding your purchase or sale of carbon credits
or offsets during the last three fiscal years and amounts budgeted for future periods.

 FirstName LastNamePatrick O'Donnell
 Comapany NameTreeHouse Foods, Inc.
 August 24, 2022 Page 3
 FirstName LastName
Patrick O'Donnell
TreeHouse Foods, Inc.
August 24, 2022
Page 3
            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 Patrick Fullem at (202) 551-8337 or Jennifer Angelini at 202-551-3047
with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing