July 30, 2024

T. Christopher Pledger
Chief Financial Officer
Westrock Coffee Co.
4009 N. Rodney Parham Road, 4th Floor
Little Rock, AR 72212

       Re: Westrock Coffee Co.
           Form 10-K for Fiscal Year Ended December 31, 2023
           Response dated July 18, 2024
           File No. 001-41485
Dear T. Christopher Pledger:

       We have reviewed your July 18, 2024 response to our comment letter and
have the
following comment.

       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. Unless we
note otherwise, any references to prior comments are to comments in our July
11, 2024 letter.

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

1.     We note your response to prior comment 1, including that "the exclusion
of Conway
       Start-up Costs are specifically permitted under the Company   s material
debt agreements
       for the purpose of determining compliance with specific financial
covenants." Please
       provide us with the following:

              the material debt agreement(s) to which Conway start-up costs are
excluded for the
            purpose of determining compliance with your material financial
covenant(s);
              whether the financial covenant is a material term of the credit
agreement; and
              the specific financial covenant(s) as calculated in accordance
with such material debt
            agreements, including the section to which it is defined in such
debt agreements.
 July 30, 2024
Page 2

       If management believes the covenant is a material term of a material
credit agreement and
       it is material to an investor's understanding of the company's financial
condition and/or
       liquidity, please disclose the following within MD&A:
           the amount or limit required for compliance with the covenant; and
           the actual or reasonably likely effects of compliance or
non-compliance with the
            covenant on the company's financial condition and liquidity.

       If you determine Adjusted EBITDA is not a material debt covenant to your
material debt
       agreements or is calculated differently from your debt agreements,
revise your non-GAAP
       measure to remove the adjustment for such start-up costs. Refer to
Question 102.09 of
       the C&DIs on Non-GAAP Financial Measures.
       Please contact Dale Welcome at 202-551-3865 or Jean Yu at 202-551-3305
if you have
questions regarding comments on the financial statements and related matters.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of
Manufacturing