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 June 2, 2025

Paulo Bonifacio
Chief Executive Officer
BRB Foods Inc.
Rua Doutor Eduardo de Souza Aranha
387 Conjunto 151
Sao Paulo, SP, Brazil 04543-121

 Re: BRB Foods Inc.
 Amendment No. 10 to Registration Statement on Form S-1
 File No. 333-276557
 Filed on May 13, 2025
Dear Paulo Bonifacio:

 We have reviewed your amended registration statement and have the
following
comments.

 Please respond to this letter by amending your registration statement
and providing
the requested information. If you do not believe a comment applies to your
facts and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

 After reviewing any amendment to your registration statement and the
information
you provide in response to this letter, we may have additional comments. Unless
we note
otherwise, any references to prior comments are to comments in our September
16, 2024 letter.

Amendment No. 10 to Registration Statement on Form S-1
Summary, page 2

1. You state on page 2 that the increased monetary policy rate "meant an
increase in the
 cost of working capital financing, which also reduced the availability
of credit lines,
 and significantly increased financial expenses from US$1,466,976 in
fiscal year 2023,
 to US$1,172,087 in fiscal year 2024." This change appears to reflect a
decrease in
 financial expenses. Please revise.
2. Please revise to prominently disclose in this section that your sales
have been
 suspended since the second quarter of 2024. Please clearly state where
your financial
 performance has been impacted by this suspension. For example, your
discussion of
 June 2, 2025
Page 2

 net losses for the year ended December 31, 2024 does not reference such
suspension.
 Further, please include a summary of the factors that led to a decrease
in net revenue
 from US$10,054,390 in FY 2023 to $40,463 in 2024.
Risk Factors
Risks Related to Our Business and Industry, page 11

3. Please revise to add risk factor disclosure discussing the fact that
your sales have been
 suspended since the second quarter of 2024. Where you discuss market
share,
 customers and vendors, revise to specifically address any challenges
associated with
 the suspension of sales and the obstacles you could face when you
attempt to re-
 enter the market.
Inflation and certain measures by the Brazilian government to curb inflation
may adversely
affect us., page 29

4. Please update your inflation risk factor to reflect the inflation
information as of a more
 recent date. For example, we note language that "[w]e expect that the
Selic rate will
 not decrease further in 2024".
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Operational Strategy and Logistics, page 45

5. Noting that your pause on sales will extend, at a minimum, into the
third quarter of
 2025, please expand your disclosure to more fully describe the decision
to suspend
 sales of your prior three products, the actions you have taken during
this time period
 to grow and continue your business, and the reason for the continued
pause on sales.
Strategic Planning, page 50

6. Please update the bullet points summarizing your "pillars" for strategic
planning, to
 reflect the pause in sales starting in the second quarter of 2024. For
example, but not
 limited to, you state you have 2,500 points of sale, but you currently
are not
 conducting sales.
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Results of Operations for the Years Ended December 31, 2024 and 2023, page 54

7. Please revise the disclosures in the table, and throughout the MD&A
section, to
 present expenses and losses in parentheses to appropriately reflect them
as negative
 amounts.
Liquidity and Capital Resources
Liquidity, page 55

8. We note you disclose on page 56 that your current working capital is
sufficient for
 your present requirements. We also note your disclosure on page 11
related to
 substantial doubt about your ability to continue as a going concern, and
that your
 balance sheet reflects a working capital deficit. Please revise your
disclosure to
 remove inconsistencies.
 June 2, 2025
Page 3
Cash Flows, page 56

9. Please revise the amount of cash provided by operating activities for
the year ended
 December 31, 2024 in the table and the following paragraph to reconcile
it with the
 amount from the statement of cash flows on page F-9. Also, revise the
direction of the
 amounts for the net cash provided by (used in) financing activities in
the table
 appropriately.
Independent Auditor's Report on Consolidated Financial Statements, page F-2

10. We note your disclosure on page 11 that your independent registered
public
 accounting firm included an explanatory paragraph concerning substantial
doubt
 about your ability to continue as a going concern in its report of your
financial
 statements for the years ended December 31, 2024 and 2023. Please have
your auditor
 revise its report to comply with paragraph 12 of AS 2415.
11. Please have your auditor revise its audit report to state the year the
auditor began
 serving consecutively as the company's auditor to comply with paragraph
10b of AS
 3101.
Income Statement, page F-6

12. Please present earnings per share amounts here and on page F-34 rounded
to the
 nearest cent (i.e., using only two decimal points) in order not to imply
a greater degree
 of precision than exists.
Statement of Cash Flows, page F-9

13. Please revise the labels appropriately. In this regard, it appears "(=)
Cash flows from
 investing activities" represents cash flows used in or provided by
operating activities.
 Similarly, "(=) Net cash from operating activities" appears to represent
cash flows
 used in investing activities.
Note 13. Intangible Assets, page F-20

14. Please provide us more detail as to the nature of the Other Operational
Intangible asset
 of $2,191,433 at December 31, 2024. As part of your response please
provide us the
 authoritative literature you relied upon when capitalizing this amount.
In this regard,
 please note that Staff Accounting Bulletin Topic 5.A indicates that
specific
 incremental costs directly attributable to a proposed or actual offering
of securities
 may properly be deferred and charged against the gross proceeds of the
offering.
 However, management salaries or other general and administrative
expenses may not
 be allocated as costs of the offering. Please advise or revise
accordingly.
Exhibit 23.1
Consent of Independent Registered Public Accounting Firm, page X-23

15. Please provide a consent with a conformed signature of the name of the
accounting
 firm providing the consent.

 Please contact Stephany Yang at 202-551-3167 or Claire Erlanger at
202-551-3301 if
you have questions regarding comments on the financial statements and related
 June 2, 2025
Page 4

matters. Please contact Sarah Sidwell at 202-551-4733 or Erin Purnell at
202-551-3454 with
any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Manufacturing
cc: Mitchell Lampert
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