April 8, 2019

Jon McKenzie
Principal Executive Officer
Elite Performance Holding Corp.
7687 Charleston Way
Port St. Lucie, FL 34986

       Re: Elite Performance Holding Corp.
           Amendment No. 4 to Registration Statement on Form S-1
           Filed April 1, 2019
           File No. 333-227650

Dear Mr. McKenzie :

      We have reviewed your amended registration statement 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 this letter by amending your registration statement
and providing the
requested information. If you do not believe our comments apply 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 these comments, we may have additional comments. Unless
we note
otherwise, our references to prior comments are to comments in our February 15,
2019 letter.

Form S-1/A filed April 1, 2019

Dilution, page 60

1.     Please revise your dilution table to present net tangible book value per
share (before and
       after the distribution) as of the latest balance sheet date, rather than
accumulated
       deficit/retained earnings per share. Refer to Item 506 of Regulation
S-K.
Management of Elite Performance Holdings Corporation, page 70

2.     We note disclosure on page II-56 and elsewhere that you "retained key
executives for
       nationwide sales and distribution" and that the "executive team is
comprised of former
       seasoned Coca-Cola, PepsiCo and Dr. Pepper executives that have over 120
years of
       combined experience in the beverage industry." It is unclear why such
executives are not
 Jon McKenzie
Elite Performance Holding Corp.
April 8, 2019
Page 2
      addressed on page 70. Please revise accordingly.
3.    We note disclosure on page II-60 regarding an account balance to an
affiliate of Alya
      Clark, "a member of [the] Board of Directors." We also note disclosure
regarding an
      outstanding balance to the sister of Jon McKenzie. Please revise or
advise us why you do
      not address these as related party transactions on page 71.
       You may contact Blaise Rhodes at (202) 551-3774 or Rufus Decker at (202)
551-3769 if
you have questions regarding comments on the financial statements and related
matters. Please
contact David Link at (202) 551-3356 or James Lopez at (202) 551-3536 with any
other
questions.



                                                          Sincerely,

FirstName LastNameJon McKenzie                            Division of
Corporation Finance
                                                          Office of Beverages,
Apparel and
Comapany NameElite Performance Holding Corp.
                                                          Mining
April 8, 2019 Page 2
cc:       Matheau J. W. Stout
FirstName LastName