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Mail Stop 3561          July 15, 2008  American Vanguard Corporation James A. Barry-Chief Financial Officer 4695 MacArthur Court  Newport Beach, California
Re:  American Vanguard Corporation
 Form 10-K for the year ended December 31, 2007
Filed March 17, 2008
  File Number: 001-13795

Dear Mr. Barry:

 We have reviewed your filing and have the following comments.  We
think you should revise your future filings in response to these comments.  If you disagree, we will consider your explanation as to why our comments are inapplicable or a revision is unnecessary.  Please be as detailed as necessary in your explanation.  In some
of our comments, we may ask you to provide us with information so we may better understand your disclosure.  After reviewing th is information, we may raise additional
comments.   Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure  requirements and to  enhance the overall
disclosure in your filing.  We look forward to  working with you in these respects.  We
welcome any questions you may have about our comments or any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.

Please respond to confirm that such comments will be complied with, or, if
certain of the comments are deemed inappropr iate, advise the staff of your reason.  Your
response should be submitted in electronic form, under the label “corresp” with a copy to the staff.  Please respond w ithin ten (10) business days.

James A. Barry-Chief Financial Officer
American Vanguard Corporation
July 15, 2008 Page 2  Form 10-K for the fiscal year ended December 31, 2007

 Item 7-Management’s Discussion and Analys is of Financial Condition and Results of
Operations

Results of Operations, page 25

1. We note your discussion and analysis of costs of goods sold is significantly
limited and in the context of gross profit,  which does not address your expenses
directly. We believe your gross profit disc losures should be supplemented with or,
preferably, replaced by a discussion and analysis of costs on a stand-alone basis (not in the context of gross profit).  Further, we believe  such disclosure should be
more comprehensive than that currently  presented and should include separate
quantification and discussion of changes in significant components of costs of
goods sold, such as direct labor and materials, producti on costs, indirect costs,
allocated general and admini strative costs, as well as independent research and
development costs.

2. A significant portion of your results of operations disc losure is dedicated to
stating, in narrative text form, dollar and percentage changes in accounts, some of
which is already included in tables.  In  addition, while you discuss certain factors
to which changes are attri butable, you do not quantify a large number of these
factors nor analyze the unde rlying business reasons for the changes.  For example,
you state that your herbicide Impact gr ew substantially in 2007, but you do not
quantify this factor nor an alyze the underlying reason for the change.  We believe
your disclosures could be improved and ma de much more user-friendly and clear
by:
• increasing the use of tables to pres ent dollar and percentage changes in
accounts, rather than including such information in narrative text form;
• using tables to list, quantify, and sum all of the material individual factors
to which changes in ac counts are attributable;
• refocusing the narrative te xt portion of the disclo sure on analysis of the
underlying business reasons for the individual factors in th e tables above;
• ensuring that all material factor s are quantified and analyzed; and
• quantifying the effects of changes in both price and volume on revenues
and expense categories, where appropriate.
With regard to refocusing the narrative te xt portion of the disclosure on analysis
of the underlying business reasons for the individual factors, we note that you
provide a more substantive disclosure of th is type of information in your earnings
conference calls than in your periodic filings on Forms 10-Q and 10-K.  We
believe much of the “color” you provide during those calls would be useful to
investors in understanding th e results of operations di sclosure in your periodic
filings and we believe you should include such analysis of the underlying business reasons for changes in results of operations in future filings.

James A. Barry-Chief Financial Officer
American Vanguard Corporation
July 15, 2008 Page 3
3. To provide investors with an unders tanding of the effects of product line
acquisitions on your growth and results  of operations, please quantify the
aggregate change in revenue and cost of  goods sold related to products not sold
for the full comparable prior period.

Contractual Obligations, page 26

4. As this table is intended to increase the tr ansparency of cash flow, we believe that
registrants should generally include scheduled interest payments in the table.
Where interest rates ar e variable and unknown, you may use your judgment to
determine whether to include such estim ates.  If you elect to include them, you
may determine the appropriate methodology to estimate the interest payments.
Regardless of whether you include interest payments or not, a footnote to the table
should clarify whether or not you have done so and, if applicable, the methodology you have used in your estimate.  If interest payments are excluded from the table, please disclose the signi ficant contractual terms of the debt and
any other additional information that is  material to an understanding of these
future cash flows.
 Liquidity and Capital Resources, page 28

5. Please revise your liquidity and capital resources disclosures to discuss the
underlying factors resulting in changes to  your cash balance, instead of merely
repeating what is shown on the statement of cash flows.  For example, we note a significant decrease in y our accounts receivable balance at December 31, 2007
without disclosure indicating the underlying reasons for th e decrease or its impact
in your operating cash flows.   Furthermore, it appears that you have and will continue to expand your business through acquisitions.  In this regard, your
disclosures should be expanded to address the impact of these acquisitions on your cash flows and operating results.  Additionally, your disclosures should provide further details regarding your overall capital structure, including a
discussion of material debt covenants and a more detailed discussion of your total
outstanding long-term debt, borrowing capacity and interest costs.

Critical Accounting Estimates, page 30

6. According to the Financial Reporting Re lease No. 72 (i.e. Release #33-8350) your
critical accounting policy disclosure should addre ss specifically why your
accounting estimates or assumptions bear the risk of change  (e.g., uncertainty
attached to the estimate or assumption, di fficulty in measuring or valuing) and, to
the extent material, factors such as how you arrived at the estimates and how
accurate the estimates/assumptions have been in the past.  In essence, your critical
accounting policies disclosure s should be expanded to address each accounting

James A. Barry-Chief Financial Officer
American Vanguard Corporation
July 15, 2008 Page 4
policy that requires management’s mo st difficult, subjective or complex
judgments.

Compensation Policies and Benchmarking, page 41

7. Your bulleted disclosure on page s 41-42 (and pages 13-14 of your proxy
statement) suggests that the compensation of your CEO and Director of Sales are
tied to company performance metrics include d in your financial plan.  In future
filings, please disclose all su ch performance targets. To the extent you believe that
disclosure of the targets is not require d because it would result in competitive
harm such that the targets could be exclude d under Instruction 4 to Item 402(b) of
Regulation S-K, please provide us with  a detailed explanation for such
conclusion.  Please also note that to the extent that you have an appropriate basis
for omitting the specific targets, you must   discuss how difficult it would be for
the named executive officers or how likel y it will be for you to achieve the
undisclosed target levels or other factors.  Ge neral statements regarding the level
of difficulty, or ease, associated w ith achieving performance goals either
corporately or individually are not sufficient.  Please provide insight into the
factors considered by the committee prior to the awarding of performance-based
compensation such as historical analyses prior to the granting of these awards or
correlations between historic al bonus practice and the incentive parameters set for
the relevant fiscal period.
 Item 8- Financial Statements and Supplementary Data

 Notes to the Financial Statements

 (4) Litigation and Environmental, page 76

8. Based on your disclosures, it appears that you are subject to si gnificant litigation.
Accordingly, we strongly encourage you to consider adding the following
disclosure in a tabular format:
• Opening loss contingency amounts,
• Increases due to loss contingenc ies recognized du ring the period,
• Increases from changes in estimates of the amounts of loss
contingencies previously recognized,
• Decreases from changes in estimates of amounts of loss contingencies
previously recognized or from derecognition of loss contingencies that are no longer probable,
• Decreases for derecognition of lo ss contingencies settled, and
• Closing loss contingency amounts.
Additionally, due to the larg e number of cases you are invo lved in; it ap pears that
the following summary disclosures would provide shareholders with a better understanding of your litigation exposure:

James A. Barry-Chief Financial Officer
American Vanguard Corporation
July 15, 2008 Page 5
• Disclosure of the total number of cases that specify damages
(including total damages claimed) and those which do not specify any
damages;
• Management’s assessment with re spect to specific litigation and
claims of the probability of incurring  material damages with respect to
litigation;
• For matters involving a large numbe r of claimants, disclosures
indicating the number of pending cases from year to year.
• Disclosures of cases which have re ached a verdict al ong with any post-
trial developments that might have at least a reasonable possibility of
affecting the final outcome;

9. On page 10 of your filing you state that you may be subject to environmental liabilities and that your use of hazardous materials exposes you to potential liabilities.  Additionally, ba sed on your disclosures on page 6, there are certain
environmental issues associated  with at least one of your f acilities.  Please tell us
whether you believe you are subject to any material asset retirement obligations under SFAS 143 and your basis for you conclusions.

10. With regard to Board of Water Supply v Shell Oil Co. et al., we note that the settlement obligated the defendants to pay for the installation of filtration devices
on other wells that became contaminated later and for the ongoing operation and maintenance of the filtration devices for up to forty years.  We also note that in June 2007, AMVAC paid $23,654 for its shar e of operations and maintenance
expenses for 2005 and 2006.  Please tell us how you accounted for the future costs of your obligation under the settlement.

Signature Pages

11. Please revise to identify your principal accounting officer.  Refer to Form 10-K.

* * * * *
 We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.
  In connection with responding to our comments, please provide, in writing, a statement from the company acknowledging that:

James A. Barry-Chief Financial Officer
American Vanguard Corporation July 15, 2008 Page 6  ‚ the company is responsible for the adequacy  and accuracy of the disclosure in the
filing;
‚ staff comments or changes to disclosure  in response to staff comments do not
foreclose the Commission from taking any action with respect to the filing; and
‚ the company may not assert staff comments as a defense in any proceeding initiated
by the Commission or any person under the federal securities laws of the United States.
 In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.
 You may contact Juan Mi gone at (202) 551-3312 or Lyn Shenk, at (202) 551-
3380 if you have questions regarding comments on the financial statements and related
matters.  Please contact the undersigned at (202) 551-3211 with any other questions.

Sincerely,

 David R. Humphrey Branch Chief