MNSTMonster Beverage

We note that you provided more expansive disclosure in your CSR report than you provided in your SEC filings. Please advise us what consideration you gave to providing the same type of climate-related disclosure in your SEC filings as you provided in your CSR report.

In response to the

Staff’s comment, the Company advises the Staff that the Company considered the Commission’s disclosure rules related to climate change and the Commission’s interpretive guidance from February 8, 2010 in preparing the Company’s 2020 Form 10-K, as reflected therein. The Company’s 2020 Form 10-K was filed with the Commission on March 1, 2021, whereas the Company’s first ever Sustainability Report (the “Sustainability Report”), was not completed and not published on the Company’s website until August 6, 2021.

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Most of the climate-related information included in the Sustainability Report, such as global energy consumption and greenhouse gas emissions, was not available at the time of the filing of the 2020 Form 10-K. The Company’s subsequent obtaining of information for, and publication of, the Sustainability Report, did not affect the Company’s view that the

2020 Form 10-K complied with the requirements of such Form and did not omit any climate-related disclosure material to investors in the context of such requirements.

As indicated in the Sustainability Report, certain information included in the Sustainability Report is based upon the sustainability and reporting framework of the Sustainability Accounting Standards Board (SASB) for the Non-Alcoholic Beverages industry of the Food and Beverage sector. Accordingly, the information included in the Sustainability Report was not based on disclosure requirements for an Annual Report on Form 10-K, and inclusion of information in the Sustainability Report is not an indication that, nor as indicated above does the Company believe that, such information is material to investors in the context of, or required to be disclosed in the 2020 Form 10-K.

The Company acknowledges the Staff’s comment and in future filings, as applicable, will continue to consider disclosure in its periodic reports of additional climate-related information included in its sustainability reports.

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Your CSR report and filing refer to certain climate-related projects. If material, please quantify past and/or future capital expenditures for climate-related projects.

In response to the

Staff’s comment, the Company advises the Staff that the Company has had no material capital expenditures for climate-related projects for the periods covered in the 2020 Form 10-K and through the date of this letter. Future capital expenditures for climate-related projects referred to in the Sustainability Report are also not expected to be material.

the Staff’s comment and in future filings, if applicable and material, will quantify capital expenditures for climate-related projects. Read in the reply ↗

To the extent applicable and if material, provide disclosure about any purchase or sale of carbon credits or offsets and any material effects on your business, financial condition, and results of operations.

In response to the

Staff’s comment, the Company advises the Staff that the Company has, through the date of this letter, not purchased or sold any carbon credits or offsets.

the Staff’s comment and in future filings, to the extent applicable and if material, will disclose the purchase and sale of carbon credits or offsets and any material effects on the Company’s business, financial condition and results of operations. Read in the reply ↗

We note from your response to prior comment 2 that you have had no material capital expenditures for climate-related projects for the periods covered in the 2020 Form 10-K and that future capital expenditures for climate-related projects are not expected to be material.

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Please tell us about your capital expenditures for climate-related projects and provide us with additional detail supporting your statements regarding materiality, including quantitative information.

In response to the Staff’s comment, the Company advises the Staff that the 2020 Form 10-K disclosed that the Company does not operate its own manufacturing facilities for finished goods, but instead outsources the manufacturing process to third-party bottlers and contract packers situated throughout the United States and abroad.

Capital expenditures for climate-related projects for all of the periods covered in the 2020 Form 10-K in aggregate were approximately $5.5 million, representing approximately 0.12% of 2020 net sales, 0.39 % of 2020 net income and 0.09% of total assets at December

Rest of the answer

31, 2020. Such climate-related projects included improvements related to LEED Gold certification for our corporate headquarters in Corona, California; incremental costs of purchasing ENERGY STAR certified coolers; and installing electric vehicle charging stations at our office in Uxbridge, United Kingdom.

for currently planned climate-related projects are estimated to be similar to our prior climate-related capital expenditures on a percentage basis. We currently estimate climate-related capital expenditures in aggregate through 2023 of approximately $9.3 million, which would represent approximately 0.20% of 2020 net sales, 0.66% of 2020 net income and 0.15% of total assets at December 31, 2020. Such climate-related projects include solar panels on the roof of our corporate headquarters in Corona, California and our warehouse in Rialto, California;

additional electric vehicle charging stations at various locations; refillable water stations throughout the corporate headquarters; and

LEED certification related features at our new facility in San Fernando, California.

Based on the above information, the Company advised the Staff that the Company has had no material capital expenditures for climate-related projects for the periods covered in the 2020 Form 10-K and that future capital expenditures for climate-related projects are not expected to be material.

However, future business opportunities or circumstances may cause a change in the Company’s estimate of capital expenditures for climate-related projects.

As stated in the

Company’s previous response letter dated October 5, 2021, the Company acknowledges the Staff’s comment and in future filings, if applicable and material, will quantify capital expenditures for climate-related projects.

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