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                            October 26, 2021

       Aldo J. Pagliari
       Chief Financial Officer
       Snap-on Incorporated
       2801 80th Street
       Kenosha, WI 53143

                                                        Re: Snap-on
Incorporated
                                                            Form 10-K for the
Fiscal Year Ended December 31, 2020
                                                            Response Dated
October 7, 2021
                                                            File No. 001-07724

       Dear Mr. Pagliari:

              We have reviewed your October 7, 2021, 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
       September 23, 2021, letter.

       Form 10-K for the Fiscal Year Ended December 31, 2020

       Item 1A
       Risk Factors, page 12

   1.                                                   Your response to prior
comment 1 refers to general disclosure of environmental regulation
                                                        and risks, and the
various risks identified in your forward-looking statement. In light of
                                                        your industry and
business operations, please tell us about the specific transition risks
                                                        related to climate
change relevant to you (such as those noted in our prior comment) and
                                                        explain how you
considered providing disclosure. Please also explain how you
                                                        determined the
materiality of their effects on your business, financial condition, and
                                                        results of operations.
 Aldo J. Pagliari
FirstName  LastNameAldo J. Pagliari
Snap-on Incorporated
Comapany
October  26,NameSnap-on
             2021       Incorporated
October
Page 2 26, 2021 Page 2
FirstName LastName
Item 7
Management's Discussion and Analysis of Financial Condition and Results of
Operations, page
27

2.       We note from your response to prior comment 2 that you have not
incurred or committed
         to incur material capital expenditures primarily for climate-related
projects. Provide us
         with support for this statement, including quantitative information.
3.       Your response to prior comment 3 appears to be conclusory in nature
without providing
         sufficient detail regarding the indirect consequences of
climate-related regulation or
         business trends, including the specific items noted in our comment.
Please describe the
         indirect consequences of climate change you considered in your
response and explain how
         you concluded they were not material.
4.       Among the disclosures cited in your response to prior comment 3 is
language which
         describes price fluctuations and supply shortages of steel and
petroleum-based energy
         sources, as well as changing vehicle requirements, but does not appear
to specifically
         relate these types of issues to climate change. Please tell us what
consideration you gave
         to identifying and analyzing these changes as indirect consequences of
climate-related
         regulation or business trends.
5.       Your response to prior comment 4 recognizes that climate change
influences weather
         patterns, indicates that you have experienced numerous significant
weather events, and
         recognizes disruptions can be costly. Tell us how you considered
providing disclosure
         discussing the significant physical effects of climate change as it
relates to its influence on
         weather patterns, such as floods, hurricanes, extreme fires, and water
availability and
         quality. In addition, please describe the weather events you have
experienced and the
         impact on your business, financial condition, and results of
operations. To the extent you
         quantified amounts, such as weather-related damages and/or the cost of
insurance, please
         provide these and explain how you analyzed materiality.
       Please contact Jennifer Angelini at 202-551-3047 or Sergio Chinos at
202-551-7844 with
any questions.



                                                                Sincerely,

                                                                Division of
Corporation Finance
                                                                Office of
Manufacturing
cc:      Richard Miller