Food, Beverage & Consumer Goods
9 SEC staff comments and 15 disclosure examples from companies in this industry.
SIC codes included: 2080 Beverages, 2000 Food and Kindred Products, 2111 Cigarettes, 2320 Men's & Boys' Furnishgs, Work Clothg, & Allied Garments, 2030 Canned, Frozen & Preservd Fruit, Veg & Food Specialties, 2086 Bottled & Canned Soft Drinks & Carbonated Waters, 2300 Apparel & Other Finishd Prods of Fabrics & Similar Matl, 2070 Fats & Oils
Disclosure examples by topic
Food, Beverage & Consumer Goods: Climate & GHG disclosures2 examplesFood, Beverage & Consumer Goods: Key performance indicators & metrics1 exampleFood, Beverage & Consumer Goods: Pensions & postretirement benefits (ASC 715)1 exampleFood, Beverage & Consumer Goods: Goodwill impairment testing1 exampleFood, Beverage & Consumer Goods: Inventory (ASC 330)1 exampleFood, Beverage & Consumer Goods: Credit losses (CECL, ASC 326)1 exampleFood, Beverage & Consumer Goods: Restructuring (ASC 420)1 exampleFood, Beverage & Consumer Goods: Leases (ASC 842)1 exampleFood, Beverage & Consumer Goods: Income tax disclosures (ASU 2023-09)1 exampleFood, Beverage & Consumer Goods: Expense disaggregation (ASU 2024-03)1 exampleFood, Beverage & Consumer Goods: Cybersecurity (Item 1C)1 exampleFood, Beverage & Consumer Goods: Variable interest entities (ASC 810)1 exampleFood, Beverage & Consumer Goods: Non-GAAP measures in MD&A1 exampleFood, Beverage & Consumer Goods: Subsequent events (ASC 855)1 example
What the SEC staff asked companies in this industry
Segment Reporting (ASC 280) (4)Goodwill & Asset Impairment (2)Fair Value & Investments (2)Non-GAAP: Adjustments & Labels (2)Non-GAAP: Reconciliation & Usefulness (2)IFRS & Foreign Private Issuers (2)Auditor & Audit Report (1)Capitalization, Equity & Escrow (1)MD&A: Results & Known Trends (1)Earnings per Share (ASC 260) (1)Risk Factors (1)Filer Status & Cover Page (1)
Under Armour, Inc. (UA, UAA) · 2026-03-11 · Form 10-K for the Fiscal Year Ended March 31, 2025 Filed May 22, 2025 · Comment 1 · Goodwill and Indefinite-Lived Intangible Assets, page 54 Agreed to revise
Staff comment: We note your disclosure that in conducting an annual impairment test, you first review qualitative factors to determine whether it is more likely than not that the fair value of the reporting unit or indefinite-lived intangible asset is less than its carrying amount, and if factors indicate that is the case, or if you choose to bypass the qualitative assessment, you perform a quantitative impairment test. We further note that no goodwill impairments were recorded during Fiscal 2025, Fiscal 2024 or Fiscal 2023. Please revise your disclosures to ensure that you include an accounting policy addressing how you assess goodwill and intangible assets for impairment. Your disclosures should… letter →
Company response: 1. The Company respectfully acknowledges the Staff’s comment and undertakes to revise our future filings, beginning with its Annual Report on Form 10-K for the year ending March 31, 2026, to enhance and expand its accounting policy disclosures related to goodwill and indefinite-lived intangible asset impairment in Note 2 to its Consolidated Financial Statements and within the Critical Accounting Estimates discussion within Management’s Discussion and Analysis of Financial Condition and Results of Operations (“MD&A”). For example, in any period that goodwill is impaired and considered a non-recurring fair value measurement, the Company will include the applicable ASC 820 disclosures, such as… response letter →
ALBANY INTERNATIONAL CORP /DE/ (AIN) · 2026-01-27 · Albany International Corp. Form 10-K for the Fiscal Year Ended December 31, 2024 Form 8-K Filed November 5, 2025 Respons · Comment 1 · Reconciliations of Non-GAAP Financial Measures, page 8 Agreed to revise
Staff comment: We considered your response to prior comment one. Presenting non-GAAP financial measures that exclude the CH-53K program losses and related adjustments does not appear to be appropriate given the nature of your fixed price long-term contracts. In this regard, recording changes in contract estimates is a normal recurring aspect in revenue recognition for fixed price long-term contracts. Please revise your future filings to remove this adjustment. letter →
Company response: Albany International Corp. (the “Company” or “we”) respectfully submits the following response to the comment included in your letter of January 22, 2026. For your convenience, your comment is repeated below in italics followed by the Company’s response. We considered your response to prior comment one. Presenting non-GAAP financial measures that exclude the CH-53K program losses and related adjustments does not appear to be appropriate given the nature of your fixed price long-term contracts. In this regard, recording changes in contract estimates is a normal recurring aspect in revenue recognition for fixed price long-term contracts. Please revise your future filings to remove this… response letter →
MOHAWK INDUSTRIES INC (MHK) · 2025-12-19 · Form 10-K for the fiscal year ended December 31, 2024 Filed February 20, 2025 · Comment 1 · Critical Accounting Policies, page 33 Responded
Staff comment: We note that you recorded material goodwill and intangible asset impairment charges in prior periods. We also note that the assessment of goodwill for impairment is identified by your auditor as a critical audit matter in their audit report. Based on the continued materiality of goodwill and intangible assets to your financial statements, underlying negative operating trends, and the fact that your net book value exceeds your market capitalization, please more fully explain to us how you determined the estimated fair values of your reporting units exceed their carrying values. In addition, to the extent you conclude an impairment charge that could materially impact your financial statements… letter →
Company response: As described in Critical Accounting Policies in the Company’s Form 10-K for the fiscal year ended December 31, 2024, the Company has identified Global Ceramic, Flooring North America (“Flooring NA”) and Flooring Rest of the World (“Flooring ROW”) as its reporting units for the purposes of allocating goodwill as well as assessing impairments. As of the Company’s 2024 annual goodwill impairment testing date, which was the first day of the fourth quarter of 2024 (the “2024 Annual Impairment Test Date”), the Company completed quantitative goodwill impairment tests (the “Annual Impairment Tests”) and determined that the estimated fair values of its reporting units with goodwill exceeded their… response letter →
MOHAWK INDUSTRIES INC (MHK) · 2025-12-19 · Form 10-K for the fiscal year ended December 31, 2024 Filed February 20, 2025 · Comment 2 · (17) Segment Reporting, page 76 Agreed to revise
Staff comment: We note you present both gross profit (loss) and operating income (loss). Please clearly identify the measure or measures of a segment’s profit or loss that the chief operating decision maker uses in assessing segment performance and deciding how to allocate resources. If the CODM uses more than one measure of a segment’s profit or loss in assessing segment performance and deciding how to allocate resources, disclose the measure required to be reported, which is the measure that management believes is determined in accordance with the measurement principles most consistent with those used in measuring the corresponding amounts in the consolidated financial statements. For each measure of a… letter →
Company response: The Company respectfully acknowledges the Staff’s comment and explains that while segment Gross profit (loss) is included in the financial information that is provided to the CODM for informational purposes, the CODM does not use segment Gross profit (loss) when assessing performance and allocating resources. The CODM uses the segment Operating income (loss) to allocate resources and assess performance. Therefore, the Company believes it is the metric required to be disclosed under the guidance in ASC 280-10-50-28A. In future filings, the Company plans to present only this required measure. To address the Staff’s comment and limit confusion on the metric used by the CODM in future filings,… response letter →
MOHAWK INDUSTRIES INC (MHK) · 2025-12-19 · Form 10-K for the fiscal year ended December 31, 2024 Filed February 20, 2025 · Comment 3 · 50-29(f) and 55-47(bb). Agreed to revise
Staff comment: We note you disclose selling, general and administrative expenses by segment. Please tell us whether any other significant segment expenses are regularly provided to the CODM or easily computable from information that is regularly provided to the CODM. In particular, tell us your consideration of presenting cost of sales by segment, which is easily computable from gross profit and net sales. In addition, for each reportable segment, disclose an amount for other segment items, along with a description of the composition of other segment items. Refer to ASC 280-10-50-26A, 50-26B and 55-15B. letter →
Company response: The Company respectfully acknowledges the Staff’s comment and confirms that the only segment expense information regularly provided to the CODM is segment Selling, general and administrative expenses. However, as both segment Net sales and segment Gross profit (loss) are also regularly provided to the CODM, segment Cost of sales is significant and easily computable from information regularly provided to the CODM. In future filings, the Company will include disclosure of segment Cost of sales in accordance with the guidance in ASC 280-10-50-26A and 55-15B. Please see the response to Comment 4 below for an illustrative example of future planned disclosures. Further, in accordance with… response letter →
MOHAWK INDUSTRIES INC (MHK) · 2025-12-19 · Form 10-K for the fiscal year ended December 31, 2024 Filed February 20, 2025 · Comment 4 · Page 3 Agreed to revise
Staff comment: Please provide reconciliations of the totals of your reportable segments' measures of profit or loss to your consolidated income before income taxes, in accordance with ASC 280-10-50-28C and 50-30(b). letter →
Company response: The Company respectfully acknowledges the Staff’s comment and confirms, as discussed above, that the only measure of segment profit/loss used by the CODM to assess performance and allocate resources is segment Operating income (loss). In future filings, beginning with the Form 10-K for the fiscal year ended December 31, 2025, the Company will update its segment disclosures and proposes to include a reconciliation of segment Operating income (loss) to consolidated Earnings (loss) before income taxes in accordance with ASC 280-10-50-28C and 50-30(b). For illustrative purposes, the following is an example of the updated segment disclosure using amounts for the year ended December 31, 2024 ($… response letter →
ALBANY INTERNATIONAL CORP /DE/ (AIN) · 2025-12-15 · Albany International Corp. Form 10-K for the Fiscal Year Ended December 31, 2024 Filed February 26, 2025 Form 8-K Filed · Comment 1 · Reconciliations of Non-GAAP Financial Measures, page 8 Agreed to revise
Staff comment: We note you present several non-GAAP financial measures including Adjusted net revenues, Adjusted gross profit/(loss), Adjusted gross profit/(loss) margin, Adjusted EBITDA, Adjusted EBITDA margin, Adjusted net income, and Adjusted earnings per share attributable to the Company shareholders – diluted. We also note that these measures exclude the CH-53K loss contract reserve and program adjustments. Although disclosing the impact of material items on reported GAAP results is appropriate, it is not clear to us how you determined that presenting non-GAAP financial measures excluding this item is appropriate. Please revise future filings to remove this adjustment or explain to us how you… letter →
Company response: Albany International Corp. (the “Company” or “we”) respectfully submits the following response to the comment included in your letter of December 15, 2025 referenced above. For your convenience, your comment is repeated below in italics followed by the Company’s response. We note you present several non-GAAP financial measures including Adjusted net revenues, Adjusted gross profit/(loss), Adjusted gross profit/(loss) margin, Adjusted EBITDA, Adjusted EBITDA margin, Adjusted net income, and Adjusted earnings per share attributable to the Company shareholders – diluted. We also note that these measures exclude the CH-53K loss contract reserve and program adjustments. Although disclosing the… response letter →
Lanvin Group Holdings Ltd (LANV, LANWF) · 2025-11-28 · Lanvin Group Holdings Limited Form 20-F Filed on April 30, 2025 · Comment 1 · page 44 Awaiting / response not in dataset
Staff comment: We note you disclose that you qualify as an emerging growth company (“EGC”) and have elected not to opt out of the extended transition period for complying with new or revised accounting standards. Please be advised that the EGC accounting deferral election is not applicable to IFRS filers and revise your disclosures accordingly in future filings. The Company respectfully acknowledges the Staff’s comment. The Company, as an EGC, prepares its financial statements in accordance with International Financial Reporting Standards (“ IFRS ”) as issued by the International Accounting Standards Board and, as an IFRS filer, is not eligible to elect the extended transition period for complying with… letter →
Lanvin Group Holdings Ltd (LANV, LANWF) · 2025-11-28 · Lanvin Group Holdings Limited Form 20-F Filed on April 30, 2025 · Comment 2 · Reporting, page 131 Awaiting / response not in dataset
Staff comment: Please revise future filings to indicate the framework used by management to evaluate the effectiveness of your internal controls over financial reporting. Refer to Item 308(a)(2) of Regulation S-K. The Company respectfully submits that it will revise the disclosure under Item 15 of its future Annual Reports on Form 20-F to state that management evaluates the effectiveness of the Company’s internal control over financial reporting based on the framework in Internal Control—Integrated Framework (2013) issued by the Committee of Sponsoring Organizations of the Treadway Commission. If you have any questions regarding this letter, please contact Howie Farn of Freshfields at… letter →
Templates & resources
- AICPA & CIMA – SEC reporting resources (AICPA & CIMA · Professional body · Free / member)
- BDO Accounting, Reporting & Compliance Hub (ARCH) (BDO · Firm guide · Free)
- Deloitte DART – Roadmap Series (Deloitte · Firm guide · Free)
- Grant Thornton Insights (Grant Thornton · Firm guide · Free)
- KPMG Financial Reporting View (KPMG · Firm guide · Free)
- PwC Viewpoint (PwC · Firm guide · Free / paid)
- RSM Financial Reporting Resource Center (RSM · Firm guide · Free)
- SEC – Corporation Finance Interpretations (SEC · Regulator · Free)
- SEC – Financial Reporting Manual (SEC · Regulator · Free)
- The Monday Filer – SEC reporting Excel templates (The Monday Filer · Template vendor · Paid)
- UnfoldCFO – 10-K Disclosure Checklist (UnfoldCFO · Template vendor · See site)
- Workiva Marketplace – SEC Reporting Process Checklist (Workiva · Template vendor · Requires Workiva license)