United States securities and exchange commission logo
May 26, 2022
Julie C. Albrecht
Chief Financial Officer
Sonoco Products Company
1 N. Second Street
Hartsville, South Carolina 29550
Re: Sonoco Products
Company
Form 10-K for the
Year Ended December 31, 2021
Form 10-Q for the
Quarter Ended April 3, 2022
File No. 001-11261
Dear Ms. Albrecht:
We have limited our review of your filing to the financial
statements and related
disclosures 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 for the Year Ended December 31, 2021
Financial Statements
Notes to the Consolidated Financial Statements
1. Summary of significant accounting policies, page F-7
1. We note that Cascades
Sonoco, Inc. is listed as both a subsidiary in Exhibit 21 and a 50%
owned equity method
investment on page F-7. However, we note you have two other
50% owned entities in
Exhibit 21, Papcor (Dezhou) Packaging Material Co. Ltd., and PT
Papcor Asia Pacific
that are not listed in the table on page F-7. Please explain to us why
they are not included
in the table or revise to include disclosure in the footnotes to the
financial statements.
18. Segment reporting, page F-37
2. We note the discussion
on pages F-37 of many different product types ranging from paper
containers to wire and
cable reels. Please tell us what consideration was given to the
Julie C. Albrecht
Sonoco Products Company
May 26, 2022
Page 2
disclosure requirements outlined in ASC 280-10-50-40 and how you have
complied. Alternatively, revise your disclosure to provide the
information regarding your
products (and services) as required by the guidance.
Form 10-Q for the Quarter Ended April 3, 2022
Managment's Discussion and Analysis
Reconciliations of GAAP to Non-GAAP Financial Measures, page 34
3. We note your reconciliation of GAAP to Non-GAAP Financial Measures
adds back other
adjustments that include after-tax charges of $14,217 related to
increases in the company's
LIFO reserve and $8,193 after-tax net gain relates to certain
derivative transactions and
discrete tax adjustments, which were partially offset by non-operating
pension
charges. Please explain to in greater detail the nature of the items
that comprise others
adjustments and how the amount of each adjustment was determined.
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 Heather Clark at 202-551-3624 or Jean Yu at 202-551-3305
with any
questions.
FirstName LastNameJulie C. Albrecht Sincerely,
Comapany NameSonoco Products Company
Division of
Corporation Finance
May 26, 2022 Page 2 Office of
Manufacturing
FirstName LastName