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                              September 15, 2023

       Jarrod Langhans
       Chief Financial Officer
       Celsius Holdings, Inc.
       2424 N. Federal Highway, Suite 208
       Boca Raton, FL 33431

                                                        Re: Celsius Holdings,
Inc.
                                                            Form 10-K for the
Fiscal Year Ended December 31, 2022
                                                            Response dated
September 6, 2023
                                                            File No. 001-34611

       Dear Jarrod Langhans:

              We have reviewed your September 6, 2023 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 24, 2023 letter.

       Form 10-K

       Management's Discussion and Analysis of Financial Condition and Results
of Operations, page
       22

   1.                                                   We note your response
to prior comment 2 reflects that you track shifting customer
                                                        preferences and
expectations, as well as technological advances in manufacturing and
                                                        distribution, and
utilize third party data to understand the latest market data and consumer
                                                        insights, and that you
have not identified any correlating trends that indicate that
                                                        sustainability was not
the primary driver for purchase conversion for your customer base.
                                                        Please clarify the
meaning of purchase conversion and its relationship to climate change
                                                        regulation. Please also
explain how you evaluated the information you considered for each
                                                        of the following and
provide support for your determination of materiality:
 Jarrod Langhans
Celsius Holdings, Inc.
September 15, 2023
Page 2
             decreased demand for goods or services that produce significant
greenhouse gas
           emissions or are related to carbon-based energy sources;
             increased demand for goods that result in lower emissions than
competing products;
             increased competition to develop or utilize innovative new
products that result in
           lower emissions; and
             increased demand for generation and transmission of energy from
alternative energy
           sources.
2.    We note your response to prior comment 3 states that you did not
experience any material
      physical or operational disruptions related to the physical effects of
climate change. As
      previously requested, please provide quantitative information for the
periods covered by
      your Form 10-K regarding weather-related damages to your leased property
and
      operations, including with respect to the impact to your operations of
any weather-related
      events that affected your co-packers. Please also discuss whether your
co-packers have
      been impacted by water availability and quality, and any correlating
impact on your
      operations and results.
3.    Your response to prior comment 3 states that a portion of the insurance
costs of your
      leased properties are passed through to you. Please quantify such pass
through costs to
      you for each of the periods presented in your Form 10-K and explain
whether changes are
      expected in future periods.
4.    We note your response to prior comment 4 and reissue in part. Please tell
us whether you
      expect to purchase carbon credits or offsets in future periods.
       Please contact Michael Purcell at 202-551-5351 or Karina Dorin at
202-551-3763 with
any questions.



                                                           Sincerely,
FirstName LastNameJarrod Langhans
                                                           Division of
Corporation Finance
Comapany NameCelsius Holdings, Inc.
                                                           Office of Energy &
Transportation
September 15, 2023 Page 2
cc:       Robert W. Pommer III
FirstName LastName