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    CHAPMAN AND CUTLER LLP

     111 WEST MONROE STREET

    CHICAGO, ILLINOIS 60603

May 22,
2020

VIA EDGAR CORRESPONDENCE

David Orlic

United States Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    Re:
    First
Trust Exchange-Traded Fund VIII (the “Trust”)

    File Nos. 333-210186; 811-23147

Dear Mr. Orlic:

This letter
responds to your comments, provided by telephone on May 4, 2020, regarding the registration statement filed on Form N-1A for
First Trust Exchange-Traded Fund VIII (the “Trust”) with the staff of the Securities and Exchange Commission
(the “Staff”) on March 10, 2020 (the “Registration Statement”). The Registration Statement
relates to the FT Cboe Vest U.S. Equity Buffer Strategy ETF (the “Fund”), a series of the Trust. Capitalized
terms used herein, but not otherwise defined, have the meanings ascribed to them in the Registration Statement.

Comment 1 – General

Please advise
whether the Fund will receive a 19b-4 order prior to launch.

Response to Comment 1

The Fund will
not receive a 19b-4 order and intends to rely on the generic listing standards and/or Rule 6c-11 under the Investment Company Act
of 1940 (the “1940 Act”).

Comment 2 – General

Please include
hyperlinks for all exhibits.

Response to Comment 2

The Fund confirms
that all exhibits that are required to do so will include a hyperlink pursuant to the FAST Act.

Comment 3 – General

Please confirm
that the Fund will not provide enhanced returns, either directly or indirectly.

Response to Comment 3

The Fund confirms
that it does not intend to provide enhanced returns, either directly or indirectly.

Comment 4 – General

The Staff requests
that the Fund file a BXT until all of the Staff’s comments are resolved.

Response to Comment 4

The Fund desires
to maintain its current effective date pursuant Rule 485A; however, the Fund intends to delay its public launch until it has addressed
the Staff’s concerns to the extent practicable.

Comment 5 – Cover
Page

Please
consider including all of the same disclosures on the cover page as those that were included on the cover pages of the Underlying
ETFs’ prospectuses, modified as necessary.

Response to Comment 5

In
response to the Staff’s comment, modified disclosure from the cover pages of the Underlying ETFs’ prospectuses
has been included on the Fund’s cover. Please see attached hereto as Exhibit A.

Comment 6 – Principal
Investment Strategies

Please consider
adding additional disclosure explaining the rolling nature of the strategy to clarify how it refreshes on a 90-day basis.

Response to Comment 6

In response
to the Staff’s comment, the following disclosure has been added in bold to the fourth (previously third) and new fifth paragraphs
of the section entitled “Principal Investment Strategies”:

This means that approximately
every 90 days, one of the Underlying ETFs will undergo a “reset” of its cap and buffer, providing the Fund with a rolling
exposure to capped and buffered returns on SPY (through the Underlying ETFs) based on the price level of SPY every 90 days.

The Fund intends to generally
rebalance its portfolio to equal weight (i.e., 25% per Underlying ETF) quarterly, in connection with the reset of each Underlying
ETF. In between such rebalances, market movements in the prices of the Underlying ETFs may result in the Fund having temporary
larger exposures to certain Underlying ETFs compared to others. Under such circumstances, the Fund’s returns would be more
greatly influenced by the returns of the Underlying ETFs with the larger exposures.

Comment 7 – Principal
Investment Strategies

Please disclose
whether the Fund will only invest in an Underlying ETF at the start of its Target Outcome Period.

Response to Comment 7

In response
to the Staff’s comment, the following disclosure has been added in bold to the new fifth paragraph of the section entitled
“Principal Investment Strategies”:

The Fund may purchase shares
of an Underlying ETF on a day other than on the first day of a Target Outcome Period and/or sell Underlying ETF shares prior to
the end of a Target Outcome Period, meaning that the Fund may experience results that are very different from the target outcomes
sought by the Underlying ETF for that Target Outcome Period.

Comment 8 – Principal
Investment Strategies

Please disclose
whether the Fund will only purchase shares of the Underlying ETFs in the secondary market. If the Fund intends to participate in
any primary or in-kind purchases, please provide an analysis under Section 17(a) of the 1940 Act.

Response to Comment 8

In response
to the Staff’s comment, the following disclosure has been added to the new fifth paragraph of the section entitled “Principal
Investment Strategies”:

The Fund intends only to purchase
shares of Underlying ETFs in the secondary market and will not engage in any principal transactions with the Underlying ETFs.

Comment 9 – Principal
Investment Strategies

Please disclose
that the Fund’s assets will be allocated equally among the Underlying ETFs or, alternatively, please disclose any circumstances
in which that will not be the case as well as any risks associated with less than equal allocation.

Response to Comment 9

Please see
Response to Comment 6.

Comment 10 – Principal
Risks

Please disclose
the risks particular to this Fund, rather than the pass-through risks of the Underlying ETFs.

Response to Comment 10

In response
to the Staff’s comment, the following disclosure has been added to the sections entitled “Principal Risks”:

BLENDED
RETURN RISK. An investment in the Fund may provide returns that are lower than the returns that an investor could achieve by
investing in one or more of the Underlying ETFs alone. Additionally, if one or more of the Underlying ETFs has exceeded its cap
at the time that you invest in the Fund, you may derive no benefit from the Fund’s investment in that Underlying ETF. Likewise,
if one or more of the Underlying ETFs has decreased in value below its buffer at the time that you invest in the Fund, you may
derive no buffered protection from the Fund’s investment in that Underlying ETF. Se Buffered Loss Risk, Capped Upside Risk
and Downside Risk below.

Comment 11 – Principal
Investment Strategies

Please disclose
how and when rebalancing will occur. Also, please explain how the Fund will handle an Underlying ETF whose price has departed significantly
from its underlying net asset value, or an Underlying ETF that does not have significant enough assets to be a viable investment
option for the Fund.

Response to Comment 11

Please see
Response to Comment 6. The Fund does not believe that a premium and/or discount in the trading price of an Underlying ETF relative
to its net asset value, or the size of an underlying ETF, will have a material impact on the Fund’s ability to execute its
investment strategy. The Fund also expects the arbitrage mechanisms of the Underlying ETFs to efficiently maintain an acceptable
correlation between the respective trading prices and net asset values of the Underlying ETFs under normal market conditions.

Comment 12 – Principal
Investment Strategies

Given that
the various caps and buffers of the Underlying ETFs are set at different price points throughout the year, please consider disclosing
whether this would dilute their combined effect at the Fund level.

Response to Comment 12

As described
in the Fund’s prospectus, the Fund itself does not intend to provide a cap or buffer with respect to the performance of SPY,
but simply a blended return of the Underlying ETFs.

In response
to the Staff’s comment, the following disclosure (underlined for purposes of this Response) has been added in bold to the
first paragraph of the section entitled “Principal Investment Strategies”:

The Fund itself does not provide
any buffer against losses. The Fund simply seeks to provide the blended return of the Underlying ETFs. In order to understand
the Fund’s strategy and risks, it is important to understand the strategies and risks of the Underlying ETFs. See below
for a discussion of the principal investment strategies of the Underlying ETFs.

Comment 13 – Principal
Investment Strategies

The Staff notes
the reference to “price return” in the first sentence in the section entitled “Principal Investment Strategies”
and asks the Fund to please advise whether this concept was included the Underlying ETFs’ disclosure.

Response to Comment 13

The Fund confirms
that this concept has been included in the Underlying ETFs’ investment objectives.

Comment 14 – Principal
Investment Strategies

Please clarify
the reference to the section entitled “SPY” at the end of the second paragraph in the section entitled “Principal
Investment Strategies.”

Response to Comment 14

This reference
has been replaced with a reference to the section entitled “SPDR® S&P 500® ETF Trust.”

Comment 15 – Principal
Investment Strategies

Please include
more disclosure regarding the current parameters of the Underlying ETFs. For example, please consider disclosing the actual caps
of the Underlying ETFs, both before and after expenses. The Staff recognizes that these parameters will change and asks the Fund
to consider whether the sticker procedures of the Underlying ETFs could be replicated for the Fund. The Staff also notes that some
disclosure was included for the Underlying ETFs but not for the Fund and asks the Fund to please consider whether that disclosure
should be included in the Fund’s prospectus. For example, the Staff points to the third, fourth and fifth paragraphs in the
section entitled “Principal Investment Strategies” in the Underlying ETFs’ prospectuses.

Response to Comment 15

In response
to the Staff’s comment, the prospectus cover page has been revised to include the parameters of the Underlying ETFs as of
the date of the prospectus as well as links to the websites of the Underlying ETFs for more current information. Please see Response
to Comment 5 and Exhibit A attached hereto.

Additionally,
the following modified disclosure from the Underlying ETFs’ prospectuses has been included in the section entitled
“Principal Investment Strategies”:

On the first day of each new
Target Outcome Period, an Underlying ETF resets by investing in a new set of FLEX Options that will provide a new cap for the new
Target Outcome Period. This means that each Underlying ETF’s cap will change for each Target Outcome Period based upon prevailing
market conditions at the beginning of each Target Outcome Period. Each Underlying ETF’s cap and buffer, and its current price
relative to each, should be considered before investing in the Fund. Each Underlying ETF will be perpetually offered and not terminate
after the initial or any subsequent Target Outcome Period.

Each Underlying ETF’s cap
and buffer are fixed levels that are calculated in relation to SPY’s price and the Underlying ETF’s net asset value
(“NAV”) at the start of a Target Outcome Period. While the cap and buffer reference the performance of SPY over a Target
Outcome Period, each Underlying ETF expects its NAV to experience the same general price movement, cap and buffer as a percentage
gain or loss over the Target Outcome Period. As SPY’s price and the Underlying ETF’s NAV change over a Target Outcome
Period, an investor, like the Fund, acquiring shares after the start of a Target Outcome Period will likely have a different return
potential than an investor who purchased shares at the start of the Target Outcome Period. This is because while the cap and buffer
for a Target Outcome Period are fixed levels that remain constant throughout the Target Outcome Period, an investor, like the Fund,
purchasing shares at market value during a Target Outcome Period likely purchased shares at a price that is different from the
Underlying ETF’s NAV at the start of the Target Outcome Period (i.e., the NAV that the cap and buffer reference). For example,
if the Fund purchases shares of an Underlying ETF during a Target Outcome Period at a time when the Underlying ETF has decreased
in value from its value on the first day of the Target Outcome Period, the Fund’s buffer will essentially be decreased by
the amount of the decrease in the Underlying ETF’s value. Conversely, if the Fund purchases shares of an Underlying ETF during
a Target Outcome Period at a time when the Underlying ETF has increased in value from its value on the first day of the Target
Outcome Period, the Fund’s cap will essentially be decreased by the amount of the increase in the Underlying ETF’s
value. See “Buffer and Cap” below for additional information. In addition, the current price of SPY is likely to be
different from the price of SPY at the start of a Target Outcome Period. To achieve the target outcomes sought by an Underlying
ETF for a Target Outcome Period, the Fund must hold its shares for that entire Target Outcome Period.

Comment 16 – Principal
Investment Strategies

Please consider
disclosing the impact on the Fund of an Underlying ETF having a Target Outcome Period of less than one year and any associated
risks.

Response to Comment 16

While it is
likely that the Fund will have exposure to an Underlying ETF that has a Target Outcome Period of less than one year for a limited
amount of time immediately following its launch, the Fund does not expect there to be any material impact on the Fund’s ability
to execute its investment strategy.

Comment 17 – Principal
Investment Strategies

Please consider
revising the second bolded sentence in the section entitled “Buffer and Cap” to the following:

This means
that if SPY experiences gains for a Target Outcome Period in excess of the cap for that Target Outcome Period, neither the Underlying
ETF nor the Fund will benefit from those excess gains.

Response to Comment 17

The prospectus
has been revised in accordance with this comment.

Comment 18 – Principal
Investment Strategies

Please
consider including the charts and accompanying text that were included in the section entitled “Principal Investment Strategies”
in the Underlying ETFs’ prospectuses. Alternatively, or in addition to that disclosure, please also consider whether there
should be a composite chart or table demonstrating hypothetical performance of the Fund under certain defined circumstances.

Response to Comment 18

In response
to the Staff’s comment, the charts and a modified version of the accompanying text that were included in the Underlying ETFs’
prospectuses have been included in the section entitled “Principal Investment Strategies.” See attached hereto as Exhibit
B.

Comment 19 – General

Please add
a concentration policy to the sections entitled “Principal Investment Strategies and “Additional Information on the
Fund’s Investment Objective and Strategies” and revise the policy stated in the Fund’s Statement of Additional
Information (“SAI”) with the following.

The Fund
may not invest 25% or more of the value of its total assets in securities of issuers in any one industry or group of industries
except to the extent that the underlying referenced index of the Underlying ETFs invests more than 25% of its assets in an industry
or group of industries. This restriction does not apply to obligations issued or guaranteed by the U.S. government, its agencies
or instrumentalities.

Response to Comment 19

The prospectus
and SAI have been revised in accordance with this comment.

Comment 20 – General

Please consider
whether disclosure should be included regarding recent market events surrounding the global COVID-19 pandemic.

Response to Comment 20

The Fund confirms
that both the Fund’s prospectus and SAI have been revised to include risk disclosure related to the global COVID-19 pandemic.

Comment 21 – Principal
Risks

Please revise
the order in which risks are disclosed to prioritize those that are most likely to adversely affect the Fund’s net asset
value, yield and total return in accorda