SecProbe.io

March 19, 2013

Via E -mail
David T. Johnson
Chief Financial Officer
American Vanguard Corporation
4695 MacArthur Court
Newport Beach, California 92660

Re: American Vanguard Corporation
  Form 10 -K for Fiscal Year Ended December 31, 2011
             Filed on March 9, 2012
             File No. 001 -13795

Dear Mr. Johnson :

We have reviewed your response letter dated January 18, 2013  and have the following
comments. In our comments, we ask you to provide us with information so we may better
understand your disclosure.

Please r espond to this letter within 10  business days by confirming that you will revise
your document in future fili ngs and providing  any reque sted information.   If you do not believe
our comments apply to your facts and circumstances, please  tell us why in your response.

After reviewing the information you provide in response to these  comments, we may
have  additional comments.

Form 10 -K for Fiscal Year Ended December 31, 2011

Item7. Management’s Discussion and Analysis of  Financial Condition and Results of
Operations

Results of Operations, page 19

1. We note your response to prior comment 3. It appears that you have only partial ly
addressed our comment and as such we reissue in part our previous comment. Please
revise your disclosure to separately quantify and discuss of changes in significant
components of cost of sales that caused costs of sales to mat erially vary (or not vary
when expected to). Additionally, the impacts of material variances in components of
costs of sales that offset each other should be separately disclosed and quantified. In this
regard, while you discuss certain factors to which ch anges are attributable, you do not

David T. Johnson
American Vanguard  Corporation
March 19, 2013
Page 2

 quantify certain of these factors nor analyze the underlying business reasons for the
changes. For example, in your response you attribute the change in costs of sales, in part,
your focus on selling those products with h igher margins or lower cost, but you do not
quantify this factor.

We believe your disclosures could be improved and made more user -friendly by:

 using tables to list, quantify, and sum all of the material individual factors to
which changes in accounts are attributable;
 refocusing the narrative text portion of the disclosure on analysis of the
underlying business reasons for the individual factors in the tables above; and
 ensuring that all material factors are quantified and analyzed.

Please provide us with a copy of your intended revised disclosure.

2. We note your response to prior comment 4.  Since you have confirmed that program costs
are material and have the potential to cause significant and unexpected fluctuations in
your reported results, please r evise to disclose the reported programs costs for each
period. Additionally, please revise your liquidity discussion to discuss program costs paid
during the year. Please provide us with a copy of your intended revised disclosure.

You may contact Aamira Chaudhry at 202 -551-3389 if you have questions regarding
comments on the financial statements and related matters.  You may also contact me at 202 -551-
3380.

Sincerely,

 /s/ Lyn Shenk

 Lyn Shenk
Branch Chief