November 20, 2018

Howard Curd
Chief Executive Officer
UNIROYAL GLOBAL ENGINEERED PRODUCTS, INC.
1800 2nd Street Suite 970
Sarasota, Florida 34236

       Re: UNIROYAL GLOBAL ENGINEERED PRODUCTS, INC.
           Form 10-K
           Filed March 19, 2018
           Definitive Proxy Statement on Schedule 14A
           Filed April 27, 2018
           File No. 000-50081

Dear Mr. Curd:

       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 filed March 19, 2018

Definitive Proxy Statement on Schedule 14A
Executive Compensation
Overview, page 11

1.    In future filings, please revise to identify the items that comprise the
Other Compensation
      component of your named executive officers' compensation. Please refer to
Item
      402(o)(7) of Regulation S-K.
 Howard Curd
UNIROYAL GLOBAL ENGINEERED PRODUCTS, INC.
November 20, 2018
Page 2
Certain Relationships and Related Transactions, page 11

2.       We note on April 1, 2018 Mr. Curd purchased from the Company a life
insurance policy
         on his life. In future filings, please disclose all information
required by Item 404 of
         Regulation S-K regarding this transaction, including the purchase
price.
3.       We note your disclosure that Mr. Curd owns the company that leases to
the Company the
         production facility in Wisconsin. In future filings, please revise to
provide all of the
         information required by Item 404 of Regulation S-K regarding this
transaction, including
         the approximate dollar value of the amount involved in the
transaction. In future filings,
         please also revise to clarify whether the lease referenced in the
fourth paragraph of this
         section is the same lease referenced in the first paragraph, or
provide the information
         required by Item 404 of Regulation S-K for each transaction.
4.       We note your disclosure that the management agreement with a company
owned by Mr.
         Curd was assigned to you at the time of the UEP acquisition. In future
filings please
         clarify whether this agreement is still in force, and if so, provide
the disclosure required by
         Item 404 of Regulation S-K, to the extent applicable.
        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 Scott Anderegg, Staff Attorney, at 202-551-3342 or Lisa
Kohl, Legal
Branch Chief, at 202-551-3348 with any questions.



FirstName LastNameHoward Curd            Sincerely,
Comapany NameUNIROYAL GLOBAL ENGINEERED PRODUCTS, INC.
                                         Division of Corporation Finance
November 20, 2018 Page 2                 Office of Consumer Products
FirstName LastName