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                              October 25, 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 R. Steve Kinsey:

              We have reviewed your September 29, 2022 response to our comment
letter 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. Unless we note otherwise, our references to prior comments are
to comments in our
       August 26, 2022 letter.

       Form 10-K for the Fiscal Year ended January 1, 2022

       Properties, page 21

   1.                                                   We understand from your
response to prior comment one that you considered but did not
                                                        select one alternative
for disclosing information that would reasonably inform investors as
                                                        to the productive
capacity and extent of utilization of your principal physical properties to
                                                        comply with Instruction
1 to Item 102 of Regulation S-K.

                                                        You explain that you do
not believe detailed information for each bakery would materially
                                                        enhance an investors
understanding of your business though do not address other
                                                        alternatives. We note
that you have proposed disclosure to explain that your bakeries
                                                        "have adequate
production utilization" and are "able to meet" current requirements.
 R. Steve Kinsey
FirstName LastNameR.  Steve Kinsey
Flowers Foods, Inc.
Comapany
October 25,NameFlowers
            2022       Foods, Inc.
October
Page 2 25, 2022 Page 2
FirstName LastName
         While we do not object to your view on the utility of the disclosure
approach considered
         and described in your response, we believe that you should
nevertheless consider other
         alternatives and formulate disclosure that is responsive to this
requirement.

         As described in Instruction 1 to Item 102, productive capacity and the
extent of utilization
         may be provided on a collective basis if appropriate, as for similar
types of facilities.

         For example, if there are notable differences in utilization of
bakeries engaged in
         production versus production and sales, a distinction introduced in
your prior response,
         you may address this requirement on a collective basis for these two
groups.

         Please also clarify the extent of any reliance on third party
manufacturers in meeting
         demand to provide context for your utilization metrics and in
describing your facilities as
         adequate and able to meet current requirements. We reissue prior
comment one.
Management's Discussion and Analysis
Results of Operations, page 33

2.       We note that you have declined to comply with prior comment two,
seeking disclosure
         of volumes that correlate with the branded retail, store branded
retail, and non-retail
         revenues that you report on page 33, and disaggregation of the
analysis of changes in total
         revenues on a similar basis to comply with Item 303(b) and (b)(2)(iii)
of Regulation S-K.

         You explain that you do not believe further details would materially
enhance an
         investors understanding of your business or operating results, and
would be competitively
         harmful because it would give competitors detailed insight into your
sales strategy.

         However, your statements about volumetric changes in revenue
categories and
         components do not appear to have adequate context, without
quantification of the actual
         volumes sold in any period, or of the actual changes in volumes sold.

         For example, the following disclosure excerpts from page 34 do not
describe the extent to
         which changes in revenues are attributable to changes in prices or to
changes in the
         volume or amount of goods being sold, or to the introduction of new
products.

                "In Fiscal 2021, the company has experienced a favorable sales
mix of branded retail
              sales....The mix of branded retail sales to total sales remained
consistent with Fiscal
              2020 which benefitted from increased demand...."

                "We continued to invest in our brands in Fiscal 2021, including
targeting the e-
              commerce channel which has experienced significant growth during
the ongoing
              pandemic. Improved promotional efficiency (measurement of a
promotion   s impact
              on operating performance) in the current year also mitigated the
sales decrease."
 R. Steve Kinsey
FirstName LastNameR.  Steve Kinsey
Flowers Foods, Inc.
Comapany
October 25,NameFlowers
            2022       Foods, Inc.
October
Page 3 25, 2022 Page 3
FirstName LastName
                "Branded retail sales declined...Positive pricing actions and
favorable mix shifts in
              Fiscal 2021 mostly offset volume declines. We experienced a
significant increase in
              prior year volumes as a result of the onset of the pandemic and
the impact of the
              additional week. Sales of our branded traditional loaf breads
experienced the largest
              declines as we focused production on these items in the prior
year...."

                "Both our DKB organic products and Canyon Bakehouse gluten-free
products
              continued to experience volume growth in Fiscal 2021 which
partially offset the
              branded retail sales decline. Fiscal 2021 volumes were still
significantly higher than
              our historical pre-pandemic levels."

                "Store branded retail sales declined significantly due to
decreased volume for store
              branded breads, buns and rolls...partially offset by increased
sales of store branded
              cake and gluten-free products."

                "Sales of our store branded retail products had been
declining...and we have
              experienced an acceleration of this trend during the pandemic,
partly due to executing
              on our strategy to prioritize a more favorable sales mix of
branded retail sales."

         While we would not object if you prefer to limit disclosures of
volumetric changes to
         directional remarks when discussing individual components of the
revenue categories that
         are not individually exhibiting material effects, we continue to
believe that you should
         provide meaningful volumetric measures that correlate with your
principal revenue
         categories to provide adequate context for the discussion and
analysis.

         However, we expect that you have alternatives for quantifying this
information. Please
         describe for us the various volumetric measures that are utilized to
manage operations for
         each of the principal revenue categories and products within those
categories, and explain
         how you have considered the comparative utility of these measures for
disclosure.

         Tell us how knowledge of volumes associated with revenues would
constitute "detailed
         insight into your sales strategy," as you have expressed, and how this
concern would vary
         among and the volumetric alternatives. It should be clear how such
disclosure would not
         simply reinforce and clarify disclosures that you have already made,
including those noted
         above, also considering remarks made during earnings calls and in
other forums.

         For example, the transcript of your 2022 second quarter earnings call
includes the
         statements "our goal over time is to not only grow dollars but
continue growing our unit
         share," "we saw private label gain a little bit of unit share, 10
basis points of unit share,"
         "overall private label units, they were down almost 8 million units in
the quarter," and
         "DKB's unit declines were primarily in California and the mass
channel." We also see
         average unit prices disclosed for several retail brands in your
September 8, 2022
         presentation for the Barclays Global Consumer Staples Conference on
your website.
 R. Steve Kinsey
Flowers Foods, Inc.
October 25, 2022
Page 4

         In conjunction with the foregoing, please explain to us how you have
calculated the
         percentage change in revenue attributed to "Pricing/mix" on page 33
and submit for our
         review detailed computations of all three percentages presented in the
tabulation.

         If the Pricing/mix percentage reflects volumetric changes (e.g.
selling fewer store branded
         retail products and a greater number of branded retail products at
higher prices), also tell
         us your rationale for this approach and how the percentage of the
change in revenue that is
         attributed to volume would be representationally faithful, in your
view.

         Please submit for our review the incremental revisions that you
believe would resolve
         the concerns outlined above or if you would like us to further
consider your position, also
         provide us with schedules of revenues and volumes for each category of
revenues and
         corresponding details for material products within these groups for
each period.
       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.
                                                               Division of
Corporation Finance
October 25, 2022 Page 4                                        Office of Energy
& Transportation
FirstName LastName