April 8, 2020

Mark Shamber
Chief Financial Officer
SpartanNash Co
850 76th Street, S.W.
Grand Rapids , Michigan 49518

       Re: SpartanNash Co
           Form 10-K for the Fiscal Year Ended December 28, 2019
           Filed February 26, 2020
           File No. 0-31127

Dear Mr. Shamber:

       We have reviewed your filing 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 filed February 26, 2020

General , page 1

1.    Please tell us your consideration of including a table of contents which
cross
      references the location of information required by the items of Form
10-K. Refer to
      General Instruction H(2) of Form 10-K.
Note 4. Property and Equipment, page 53

2.    Please tell us your consideration of disclosing the amount of
depreciation expense for the
      years provided. Refer to ASC 360-10-50-1.
Note 13. Income Tax, page 67

3.    Please tell us your consideration of disclosing the nature of the tax
credits utilized in the
      2019 effective income tax rate reconciliation. Refer to ASC 740-10-50-12.
 Mark Shamber
SpartanNash Co
April 8, 2020
Page 2
Note 17. Reporting Segment Information, page 71

4.       Please tell us why depreciation and amortization totals do not agree
to depreciation and
         amortization disclosed in the statements of cash flows. Further,
please provide a
         reconciliation of the total of the reportable segment's depreciation
and amortization
         expense for each segment to your consolidated depreciation and
amortization expense.
         Refer to ASC 280-10-50-30.
Item 9A. Controls and Procedures, page 74

5.       Please tell us your consideration of disclosing any changes in your
internal control over
         financial reporting that occurred during your last fiscal quarter that
has materially
         affected, or is reasonably likely to materially affect your internal
control over financial
         reporting. Refer to Item 308(c) of Regulation S-X.
        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 Tony Watson at (202) 551-3318 or Donna Di Silvio at (202)
551-
3202 with any questions.



FirstName LastNameMark Shamber                                  Sincerely,
Comapany NameSpartanNash Co
                                                                Division of
Corporation Finance
April 8, 2020 Page 2                                            Office of Trade
& Services
FirstName LastName