Mail Stop 4628

                                                             September 18, 2018

Via E-mail
Anthony J. Allott
President and Chief Executive Officer
Silgan Holdings Inc.
4 Landmark Square, Suite 400
Stamford, CT 06901

       Re:     Silgan Holdings Inc.
               10-K for Fiscal Year Ended December 31, 2017
               Filed March 1, 2018
               File No. 0-22117

Dear Mr. Allott:

        We have limited our review of your filing to your contacts with
countries that have been
identified as state sponsors of terrorism, and we have the following comment.
Our review with
respect to this issue does not preclude further review by the Assistant
Director group with respect
to other issues. In our comment, we 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.

General

1.     You indicate on page 10 of the 10-K that your customer Nestl  accounted
for
       approximately 11% of your consolidated net sales in 2017. The Nestl
website indicates
       that a Nestl  subsidiary headquartered in Cairo, Egypt covers Sudan, and
we are aware of
       a news report indicating that this subsidiary exports products to Sudan.
Additionally,
       Nestl 's 2017 Annual Report indicates that Nestl  imports products into
Syria. In a letter
       to the staff dated December 12, 2014, you discussed your subsidiaries'
sale of metal
       closures and containers to customers in Syria. Sudan and Syria are
designated by the
       Department of State as state sponsors of terrorism, and are subject to
U.S. economic
       sanctions and/or export controls.

       Please describe to us the nature and extent of any past, current, and
anticipated contacts
       with Sudan, and any such contacts with Syria since your 2014 letter,
including contacts
 Anthony J. Allott
Silgan Holdings Inc.
September 18, 2018
Page 2
       with their governments, whether through subsidiaries, affiliates,
distributors, partners,
       customers or other direct or indirect arrangements. Please also discuss
the materiality of
       those contacts, in quantitative terms and in terms of qualitative
factors that a reasonable
       investor would deem important in making an investment decision. Tell us
the
       approximate dollar amounts of revenues, assets and liabilities
associated with those
       countries for the last three fiscal years and the subsequent interim
period. Address for us
       the potential impact of the investor sentiment evidenced by divestment
and similar
       initiatives that have been directed toward companies that have
operations associated with
       U.S.-designated state sponsors of terrorism.

        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

        You may contact Daniel Leslie, Staff Attorney, at (202) 551-3876 or me
at (202) 551-
3470 if you have any questions about the comment or our review.

                                                            Sincerely,

                                                            /s/ Cecilia Blye

                                                            Cecilia Blye, Chief
                                                            Office of Global
Security Risk

cc:    Amanda Ravitz
       Assistant Director
       Division of Corporation Finance

       Frank W. Hogan, III
       Senior Vice President, General Counsel and Secretary
       Silgan Holdings Inc.