March 18, 2020 Richard Dierker Executive Vice President and Chief Financial Officer CHURCH & DWIGHT CO INC 500 Charles Ewing Boulevard Ewing, NJ 08628 Re: CHURCH & DWIGHT CO INC Form 10-K for the Fiscal Year Ended December 31, 2019 Filed February 18, 2020 File No. 001-10585 Dear Mr. Dierker: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment 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 comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Form 10-K for the Fiscal Year Ended December 31, 2019 Management's Discussion and Analysis of Financial Condition and Results of Operations Critical Accounting Policies and Estimates Impairment of goodwill, trade names and other intangible assets, page 34 1. We note that due to recent sales and profit declines, a significant portion of the excess between fair value and the carrying value of certain of your personal care trade names has eroded. To help inventors more fully understand the potential impairment risk associated with these assets, please identify each material trade name with a fair value that is not substantially in excess of its carrying value and disclose the following: the carrying value and the percentage by which fair value exceeded carrying value; and describe the variables underlying your "relief from royalty" and/or "excess earnings" discounted cash flows such that changes in those variables may result in a decline in fair value significant enough to trigger an impairment charge for the trade name. Refer to Section V of Release 33-8350. Richard Dierker CHURCH & DWIGHT CO INC March 18, 2020 Page 2 In closing, 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 Jeanne Baker at 202-551-3691 or Terence O'Brien at 202-551-3355 with any questions. FirstName LastNameRichard Dierker Sincerely, Comapany NameCHURCH & DWIGHT CO INC Division of Corporation Finance March 18, 2020 Page 2 Office of Life Sciences FirstName LastName