Mail Stop 3561

									June 23, 2005



Mr. James L. Schaeffer
Chief Executive Officer
Polymer Group, Inc.
4055 Faber Place, Suite 201
North Charleston, SC 29405

      RE:	Polymer Group, Inc.
      Form 10-K for Fiscal Year Ended January 1, 2005
      Form 10-Q for Fiscal Quarter Ended April 2, 2005
      Filed March 29, 2005 and May 16, 2005
      File No. 1-14330

Dear Mr. Schaeffer:

	We have reviewed the responses in your letter dated June 10,
2005 and have the following additional comments.  Where indicated,
we
think you should revise your document in response to these
comments.
If you disagree, we will consider your explanation as to why our
comment is inapplicable or a revision is unnecessary.  Please be
as
detailed as necessary in your explanation.  After reviewing this
information, we may raise additional comments.

	We welcome any questions you may have about our comments or
on
any other aspect of our review.  Feel free to call us at the
telephone numbers listed at the end of this letter.


Form 10-K for Fiscal Year Ended January 1, 2005

Note 11. Debt, page 61

1. We have reviewed your response to comment 13 in our letter
dated
May 18, 2005 and still do not believe it is clear why there was no
gain or loss recognition on the exchange of the Series A
convertible
pay-in-kind preferred shares for the outstanding Junior notes.  In
this regard, it appears to us that the preferred shares issued in
the
exchange were more valuable to the holders than the Junior notes.
In
particular, while both the Junior notes and the preferred shares
were
convertible into common stock at the same rate as of the exchange
date, we note that the preferred shares accrue dividends (which
accrued amount is convertible into additional common shares) at
16%,
whereas the notes only accrued interest at 10%.  Please provide us
additional support for your position that this exchange should not
result in gain or loss recognition.  Tell us the amount you would
have had to pay in cash, as of the date of the exchange, to
extinguish the Junior notes and why you believe this value is not
representative of the fair value of the convertible preferred
shares
issued.  Finally, please tell us how, after the exchange
accounting,
you determined the intrinsic value of the conversion option in the
new equity instrument.  In this regard, we note that the
conversion
option appears to have been in-the-money on the date of the
exchange.
Ensure your response addresses the applicability of APB 26 and
SFAS
84 to this transaction.  Also tell us how you considered paragraph
12
of EITF 98-5, Issues 11, 12(a), and 12(b) of EITF 00-27, and other
applicable guidance in determining the appropriate accounting for
the
exchange.

Note 19. Foreign Currency and Other, page 79

2. We have reviewed your response to comment 16 in our letter
dated
May 18, 2005 and do not believe you have adequately supported your
position that foreign currency transaction income and losses are
properly excluded from operating income.  In particular, we note
that
unless Rule 5-03.7 of Regulation S-X expressly permits
classification
of an item as non-operating, the presumption is that the item
should
be classified as an operating item.  Thus, absent compelling
evidence
that income and losses on your foreign currency transactions are
unrelated to transactions made during the ordinary course of your
operations, we believe that the gains and losses should be
classified
in operating income.  Based on the information you have provided,
it
appears that the underlying transactions which generate your
foreign
currency transaction income and losses are transactions entered
during the ordinary course of your operations, for example, in
buying
and selling products.  If you continue to believe that your
current
income statement classification is appropriate, please advise us
in
detail as to the basis for your position.  Otherwise please tell
us
how you intend to revise your filings accordingly.


		As appropriate, please respond to these comments within
10
business days or tell us when you will provide us with a response.
Detailed response letters greatly facilitate our review.  Please
understand that we may have additional comments after reviewing
your
responses to our comments.




   		You may contact Andrew Blume at (202) 551-3254 or, in
his
absence, Robyn Manuel at (202) 551-3823 if you have questions
regarding comments on the financial statements and related
matters.
Please contact me at (202) 551-3843 with any other questions.

								Sincerely,



									George F. Ohsiek, Jr.
									Branch Chief


Mr. James L. Schaeffer
Polymer Group, Inc.
June 23, 2005
Page 1