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                              April 8, 2022

       D. Andrew Edwards
       Chief Financial Officer
       TREDEGAR CORP
       1100 Boulders Parkway
       Richmond, VA 23225

                                                        Re: TREDEGAR CORP
                                                            Form 10-K for
Fiscal Year Ended December 31, 2021
                                                            Filed March 11,
2022
                                                            File No. 001-10258

       Dear Mr. Edwards:

              We have limited our review of your filing to the financial
statements and related
       disclosures 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.

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

       Management's Discussion and Analysis of Financial Condition and Results
of Operations
       Results of Operations, page 19

   1.                                                   We note your prolific
use of non-GAAP measures in your discussion of your results of
                                                        operations with little
to no discussion of your GAAP measures of profitability, such as
                                                        Net Income. We also
note that elsewhere in your document you discuss the impact of
                                                        events on EBITDA, such
as the customer product transition in your surface protection
                                                        business, without
disclosing the actual and expected impact on Net Income. In future
                                                        filings beginning with
your next quarterly report, please revise to also include discussions
                                                        of the most directly
comparable GAAP measures with equal or greater prominence. Refer
                                                        to the Compliance and
Disclosure Interpretations for Non-GAAP Financial Measures,
                                                        including Question
102.10, for guidance.
 D. Andrew Edwards
FirstName   LastNameD. Andrew Edwards
TREDEGAR       CORP
Comapany
April       NameTREDEGAR CORP
       8, 2022
April 28, 2022 Page 2
Page
FirstName LastName
Financial Statements
Note 12 - Income Taxes, page 67

2.       We note significant changes in the amount of deferred tax assets you
have recognized
         at December 31, 2021 relating to pensions and NOL and credit
carryforwards. Please tell
         us, and disclose in future filings, the drivers behind the significant
changes in the
         components of your deferred tax assets.
       In closing, 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 Kevin Stertzel at (202) 551-3723 or Martin James at (202)
551-
3671 with any questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of
Manufacturing