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                               August 26, 2022

       R. Steve Kinsey
       Chief Financial Officer
       Flowers Foods, Inc.
       1919 Flowers Circle
       Thomasville, Georgia 31757

                                                        Re: Flowers Foods, Inc.
                                                            Form 10-K for the
Fiscal Year ended January 1, 2022
                                                            Filed February 23,
2022
                                                            File No. 001-16247

       Dear Mr. Kinsey:

              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 for the Fiscal Year ended January 1, 2022

       Item 2. Properties, page 21

   1.                                                   We note that you have
limited your disclosure under this heading to a list of the locations
                                                        of 44
bakeries/production plants. Please expand your disclosure to also identify the
                                                        facilities and other
assets that comprise your distribution network and to provide details
                                                        regarding the nature or
use of your production and distribution facilities that provide some
                                                        means of
differentiation that is incremental to the geographic information.

                                                        Please also describe or
indicate the production and distribution capacities of your facilities
                                                        and the extent of
utilization for each period to comply with Instruction 1 to Item 102 of
                                                        Regulation S-K. Given
your disclosures elsewhere in the filing indicating closures and
                                                        idling of various
facilities and equipment, it would also be helpful to indicate the current
                                                        status of each facility
listed to correlate with those other disclosures.
 R. Steve Kinsey
Flowers Foods, Inc.
August 26, 2022
Page 2
Management's Discussion and Analysis
Results of Operations , page 33

2.       We understand that your revenue has been impacted by volume
fluctuations for all periods
         presented. Please expand your disclosures to include a tabulation of
volumes sold each
         period and to quantify the increase or decrease in revenue for branded
retail, store branded
         retail, and non-retail that is attributable to changes in volumes sold
and to changes in
         average prices to comply with Item 303(b) and (b)(2)(iii) of
Regulation S-K.
Financial Statements
Note 2 - Summary of Significant Accounting Policies
Fiscal Year End, page F-9

3.       We note disclosure in Note 23 on page F-57, indicating that you report
interim financial
         information based on irregular periods that do not reflect actual
quarters of your fiscal
         year, and providing a summary of    financial results that impact
comparability    although
         without addressing the effects associated with this manner of
reporting.

         We also see that you have a section called Matters Affecting
Comparability on page 33 in
         your subsequent interim reports, although without addressing
limitations on the indicative
         value of your reported financial information or the general lack of
comparability to other
         interim periods due to differences in the lengths of the interim
periods.

         Please expand the disclosures under this heading to describe your
interim reporting
         convention and your business reasons for not reporting interim results
based on actual
         quarters of equal length. Please expand the disclosures in your
interim reports to also
         include those reasons and prominent cautionary language in Note 1 and
under Matters
         Affecting Comparability in MD&A, to advise readers that your interim
results may not be
         indicative of subsequent interim period results, or comparable to
prior or subsequent
         interim period results, due to differences in the lengths of the
interim periods.
        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 Lily Dang at (202) 551-3867 or John Cannarella at (202)
551-3337 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Karl Hiller, Branch Chief, at (202) 551-3686 with any other questions.



FirstName LastNameR. Steve Kinsey                              Sincerely,
Comapany NameFlowers Foods, Inc.
August 26, 2022 Page 2                                         Division of
Corporation Finance
FirstName LastName                                             Office of Energy
& Transportation