December 19, 2024

William Drew
Chief Financial Officer
Ranpak Holdings Corp.
7990 Auburn Road
Concord Township, OH 44077

       Re: Ranpak Holdings Corp.
           Form 10-K for Fiscal Year Ended December 31, 2023
           Filed March 14, 2024
           Form 8-K Filed March 11, 2024
           File No. 001-38348
Dear William Drew:

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

       Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this letter, we may have additional
comments.

Form 10-K for Fiscal Year Ended December 31, 2023
Item 7. Management's Discussion and Analysis of Financial Condition and Results
of
Operations
Results of Operations, page 30

1.     Your discussion of changes in cost of goods sold cites multiple factors
as impacting
       your results of operations but provides no quantification of the
contribution of each
       factor. Where one or more factors contribute to material changes in
operating results,
       please revise future filings to describe and explain the underlying
reasons for
       the changes in quantitative and qualitative terms. Refer to the guidance
in Item 303(b)
       of Regulation S-K.
 December 19, 2024
Page 2
Presentation and Reconciliation of GAAP to Non-GAAP Measures, page 33

2.    We note your non-GAAP adjustments for "cloud-based software
implementation
      costs", "SOX remediation costs", and other. Please describe to us, in
greater detail,
      the specific nature of each adjustment and explain how you determined it
is
      appropriate based on the guidance in Question 100.01 of the Division of
Corporation
      Finance's Compliance & Disclosure Interpretations on Non-GAAP Financial
      Measures since it appears the adjustments may represent normal operating
expenses
      related to your business. This comment is also applicable to disclosures
in Earnings
      Releases filed under Form 8-K.
3.    We note you present Non-GAAP Constant Currency Net Revenue and AEBITDA,
      which also includes an adjustment for constant currency. We also note you
calculate
      these measures by multiplying Euro-derived data by 1.15 to reflect an
exchange rate
      of 1 Euro to 1.15 USD, that you believe is a reasonable exchange rate to
use to give a
      stable depiction of the business without currency fluctuations between
periods and
      approximates the average exchange rate of the Euro to USD over the past
five years.
      Please more fully explain to us why you believe using an average exchange
rate over
      the past five years rather than the actual difference between the
exchange rates during
      the periods presented would be more appropriate and quantify the
difference between
      the rate you used and the actual rates. This comment is also applicable
to disclosures
      in Earnings Releases filed under Form 8-K.
Item 8. Financial Statements and Supplementary Data
Consolidated Statements of Operations, page 45

4.    We note you separately present net revenue related to products, leasing
and other.
      Please revise future filing to separately present cost of sales related
to each revenue
      line item as required by Item 5-03(b)(2) of Regulation S-X.
Form 8-K filed March 11, 2024
Exhibit 99.1
Non-GAAP Financial Data, page 8

5.    We note your reconciliations of GAAP Statement of Income Data to Non-GAAP
      Constant Currency Statement of Income Data on pages 12-15 appear to
represent non-
      GAAP income statements. Please explain to us why you believe these
reconciliations
      are appropriate based on the guidance in Question 102.10 of the Division
of
      Corporation Finance   s Compliance & Disclosure Interpretations on
Non-GAAP
      Financial Measures.
 December 19, 2024
Page 3

        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.

       Please contact Mindy Hooker at 202-551-3732 or Anne McConnell at
202-551-3709
with any questions.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of
Manufacturing