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                            September 15, 2023

       George R. Bracken
       Executive Vice President     Finance
       National Beverage Corp.
       8100 SW Tenth Street, Suite 4000
       Fort Lauderdale, FL 33324

                                                        Re: National Beverage
Corp.
                                                            Form 10-K for the
Fiscal Year Ended April 29, 2023
                                                            Response dated
September 5, 2023
                                                            File No. 001-14170

       Dear George R. Bracken:

              We have reviewed your September 5, 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 3, 2023 letter.

       Form 10-K filed June 28, 2023

       Management's Discussion and Analysis of Financial Condition and Results
of Operations, page
       12

   1.                                                   We note your response
to prior comment 1. However, it does not appear that you have
                                                        explained the basis for
you conclusion regarding materiality. Please explain in greater
                                                        detail how you
considered providing disclosure regarding the following indirect
                                                        consequences of
climate-related regulations or business trends:
                                                            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 innovative new products that result in lower
                                                            emissions; and
 George R. Bracken
National Beverage Corp.
September 15, 2023
Page 2
                increased demand for generation and transmission of energy from
alternative energy
              sources.

         We also note your response states that you did not experience
increased competition to
         develop innovative new products that result in lower emissions nor an
increased demand
         for generation and transmission of energy from alternative energy
sources. Please tell us
         how you considered discussing the indirect consequences of
climate-related regulations or
         business trends on your manufacturing, packaging and distribution
supply chain, including
         any related increased compliance costs and capital expenditures. In
that regard, we note
         you disclose that you are "dedicated to sustainable operations and
responsible business
         initiatives" and that you focus on "reducing packaging content."

         In addition, please expand your disclosure to discuss the potential
adverse consequences
         to your reputation resulting from your operations or products that
produce material
         greenhouse gas emissions.
2.       Your response to prior comment 2 appears to be conclusory in nature
without providing
         sufficient detail regarding the potential physical effects of climate
change on your
         operations and results. In that regard, we note you disclose that
during the three year
         period covered by the Form 10-K, you did not experience a material
physical effect from
         the severity of weather to your operations or results of operations
and no material
         weather-related damages to your property or operations. Please
quantify the impact of any
         severe weather on your operations and results, including the closures
of any facilities such
         as your South Florida facility.

         Please also tell us what consideration you have given to discussing
whether climate
         change may exacerbate extreme weather and impact your production and
operations. For
         example, your discussion may consider, among other factors, the
impact, if any, of the
         California wildfires or Winter Storm Uri on your facilities and/or raw
materials, and
         whether severe weather as a result of climate change may result in
water scarcity or
         deterioration of water quality. We note your raw materials disclosure
on page 7 of your
         Form 10-K and that your risk factor on page 12 states that
"[p]rolonged drought
         conditions in the geographic regions in which you do business could
lead to restrictions on
         the use of water, which could adversely affect [your] ability to
produce and distribute
         products."
       Please contact Michael Purcell at 202-551-5351 or Karina Dorin at
202-551-3763 with
any questions.



FirstName LastNameGeorge R. Bracken                            Sincerely,
Comapany NameNational Beverage Corp.
September 15, 2023 Page 2                                      Division of
Corporation Finance
FirstName LastName                                             Office of Energy
& Transportation