United States securities and exchange commission logo





                            July 21, 2022

       Heather Pomerantz
       Chief Financial Officer
       Freshpet, Inc.
       400 Plaza Drive, 1st Floor
       Secaucus, New Jersey 07094

                                                        Re: Freshpet, Inc.
                                                            Form 10-K for the
Fiscal Year Ended December 31, 2021
                                                            Response dated July
15, 2022
                                                            File No. 001-36729

       Dear Ms. Pomerantz:

               We have reviewed your July 15, 2022 response to our comment
letter 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. Unless we note otherwise, our references to prior comments are
to comments in our
       June 15, 2022 letter.

       Form 10-K for the Year Ended December 31, 2021

       Management's Discussion and Analysis of Financial Condition and Results
of Operations
       Non-GAAP Financial Measures, page 33

   1.                                                   We note your response
to comment 1. You have indicated that the non-GAAP adjustment
                                                           plant start-up costs
   includes pre-opening and ramp-up costs, such as labor, overhead,
                                                        testing and disposal
costs, incurred in connection with the start-up of new manufacturing
                                                        lines before those
lines are fully operational. We have considered your responses
                                                        carefully and continue
to believe that your non-GAAP financial measures that exclude
                                                        plant start-up costs
are inconsistent with Rule 100(b) of Reg. G. Please revise
                                                        accordingly.
 Heather Pomerantz
Freshpet, Inc.
July 21, 2022
Page 2

       You may contact Heather Clark at 202-551-3624 or Andrew Blume at
202-551-3254 with
any questions.



FirstName LastNameHeather Pomerantz                    Sincerely,
Comapany NameFreshpet, Inc.
                                                       Division of Corporation
Finance
July 21, 2022 Page 2                                   Office of Manufacturing
FirstName LastName