United States securities and exchange commission logo





                             October 19, 2021

       Joel Wine
       Chief Financial Officer
       Matson, Inc.
       1411 Sand Island Parkway
       Honolulu, HI 96819

                                                        Re: Matson, Inc.
                                                            Form 10-K for the
Fiscal Year Ended December 31, 2020
                                                            Filed February 26,
2021
                                                            File No. 001-34187

       Dear Mr. Wine:

              We have reviewed your September 27, 2021 response to our comment
letter 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. Unless we note otherwise, our references to prior comments are
to comments in our
       September 15, 2021 letter.

       Form 10-K for the Fiscal Year Ended December 31, 2020

       Management Discussion and Analysis of Financial Condition and Results of
Operations, page 26

   1.                                                   Please provide us with
additional detail supporting the statement made in response to
                                                        comment 4 that you did
not experience any material weather-related damages to your
                                                        property or operations,
including quantitative information.
   2.                                                   We note your response
to prior comment 4. Please address the significant physical effects
                                                        of climate change as it
relates to the potential for indirect weather-related impacts that
                                                        have affected or may
affect your major customers or suppliers in greater detail.

   3.                                                   Your response to prior
comment 5 states that any increase in compliance costs related to
                                                        climate change in the
periods covered by the 2020 Form 10-K were not material to your
 Joel Wine
Matson, Inc.
October 19, 2021
Page 2
         financial results. Tell us about the compliance costs you have
incurred and explain how
         you concluded the related amounts were not material.
4.       We note from your response to prior comment 6 that purchases of carbon
offsets and sales
         of carbon credits have not been material and have not had a material
effect on your
         business, financial condition or results of operations. Provide us
with additional detail to
         support this statement.
      You may contact Wei Lu, Staff Accountant at (202) 551-3725 or Ethan
Horowitz,
Accounting Branch Chief at (202) 551-3311, if you have questions regarding the
comments.



FirstName LastNameJoel Wine                                    Sincerely,
Comapany NameMatson, Inc.
                                                               Division of
Corporation Finance
October 19, 2021 Page 2                                        Office of Energy
& Transportation
FirstName LastName