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Correspondence

 VIA EDGAR AND FACSIMILE

 August 8, 2008

 David R. Humphrey

 Branch Chief

 Mail Stop 3561

 United States Securities
and Exchange Commission

 450 Fifth Street, N.W.

 Washington,
D.C. 20549

Re:

 American Vanguard Corporation

 Form 10-K for
the Year Ended December 31, 2007

 Filed March 17, 2008

 File Number: 001-13795

 Dear Mr. Humphrey:

 Below for your consideration are responses to the Staff’s comments appearing in the letter dated July 15, 2008 with respect to American Vanguard Corporation’s Annual Report on Form 10-K for the year ended December 31,
2007 filed March 17, 2008. Please note that references to “future disclosures” relate to the Company’s filings which will take place after the filing of the Company’s Quarterly Report on Form 10-Q for the quarter ended
June 30, 2008. For the sake of convenience, we have set forth the Staff’s comments in normal text and our responses in italics.

 Form 10-K for
the fiscal year ended December 31, 2007

 Item 7 - Management’s Discussion and Analysis 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 disclosures 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,

production costs, indirect costs, allocated general and administrative costs, as well as independent research and development costs.

 Response: While historically the Company’s changes in gross profit and related costs of goods sold (when comparing to prior periods) were
primarily related to product mix, the Company will make every effort to become more comprehensive in its disclosure. The focus will be on the gross profit related to the disclosed Crop and Non-crop business given the fact that substantially all of
the Company’s business is within one government SIC Code, which is 2879 Agricultural Chemicals. It should be noted that the Company does not allocate general and administrative costs or independent research and development costs to cost of
goods sold.

2.
A significant portion of your results of operations disclosure 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 attributable, you do not quantify a large number of these factors nor analyze the underlying business reasons for the changes. For example, you state that your
herbicide Impact grew substantially in 2007, but you do not quantify this factor nor analyze the underlying reason for the change. We believe your disclosures could be improved and made much more user-friendly and clear by:

•

 increasing the use of tables to present 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 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;

•

 ensuring that all material factors 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 text 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 this 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 the results of operations disclosure 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.

Response: The Company continues to make every effort to disclose the underlying factors that lead to the dollar and percentage changes. The Company
acknowledges that, from time-to-time, in its earnings conference calls, it provides certain “color”, primarily related to its responses to questions that are posed during the conference calls. The Company advises that its “trade
secrets” are primarily its sales, pricing, marketing, support and distribution relating to specific product lines which it protects from disclosure to its competitors and as such, exposing this information in a public filing would result in an
extreme competitive disadvantage. The Company competes against larger companies and the Company advises that in reviewing its competitors’ public filings, such product line information is not provided. The Company advises that while it does
reference increases and decreases in

 American Vanguard Corporation

 4695 MacArthur Court, Suite 1250, Newport Beach, CA 92660

 2

various product categories in MD&A, the intention is to provide specific disclosure without disclosing its present trade secrets. That being said, the
Company will make a concentrated effort to focus on quantifying the factors that lead to large variances and disclose the business reasons for same in its future filings without compromising its position of protecting its trade secrets.

3.
To provide investors with an understanding 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.

 Response: The Company has indicated
that substantially all of its chemical product lines are “off patent.” The Company has adopted a strategy of acquiring mature chemistries from larger competitors who have either abandoned the product line for new, more modern products they
have developed or have been forced to divest these products by trade regulators as a condition of a merger. As aforementioned, the Company advises that its “trade secrets” are primarily its sales, pricing, marketing, support and
distribution relating to specific product lines which it protects from disclosure to its competitors and as such, exposing this information in a public filing would result in an extreme competitive disadvantage. The Company competes against larger
companies and the Company advises that in reviewing its competitors’ public filings, such product line information is not provided. The Company advises that while it does reference increases and decreases in various products in MD&A, the
intention is to provide specific disclosure without disclosing its present trade secrets.

 Contractual Obligations, page 26

4.
As this table is intended to increase the transparency of cash flow, we believe that registrants should generally include scheduled interest payments in the table. Where interest
rates are variable and unknown, you may use your judgment to determine whether to include such estimates. 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 significant
contractual terms of the debt and any other additional information that is material to an understanding of these future cash flows.

 Response: The Company will either include scheduled interest payments in the contractual obligations table or include disclosure of the significant contractual terms of its debt and any other additional information that would be material
to an understanding of the future cash flows in its future filings.

 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 your accounts receivable balance at December 31, 2007 without disclosure indicating the underlying reasons for the 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

 American Vanguard Corporation

 4695 MacArthur Court, Suite 1250, Newport Beach, CA 92660

 3

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 more detailed discussion of your total outstanding long-term debt, borrowing capacity and interest costs.

 Response: The Company believes that underscoring the information on its Cash Flow Statements is helpful. The Company will enhance its disclosure by
disclosing further the reasons for large shifts in its accounts. The Company will also add disclosure outlining “Other Sources and Uses of Cash” when appropriate as well as disclosure related to its credit facility and associated bank
covenants and guarantees in its future filings.

 As stated earlier, the Company has adopted a strategy of acquiring mature
chemistries from larger competitors who have either abandoned the product line for new, more modern products they have developed or have been forced to divest these products by trade regulators as a condition of a merger. As aforementioned, the
Company advises that its “trade secrets” are primarily its sales, pricing, marketing, support and distribution relating to specific product lines which it protects from disclosure to its competitors and as such, exposing this information
in a public filing would result in an extreme competitive disadvantage. The Company advises that while it does reference increases and decreases in various products in MD&A, the intention is to provide specific disclosure without disclosing its
present trade secrets.

 As it relates to the Company’s disclosure of liquidity and capital resources, the Company will make a
concentrated effort to add additional information related to its completed acquisitions to the extent that such disclosure does not compromise the Company’s policy of not disclosing its present trade secrets.

 Critical Accounting Estimates, page 30

6.
According to the Financial Reporting Release No. 72 (i.e. Release #33-8350) your critical accounting policy disclosure should address specifically why your accounting estimates
or assumptions bear the risk of change (e.g., uncertainty attached to the estimate or assumption, difficulty 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 disclosures should be expanded to address each accounting policy that requires management’s most difficult, subjective or complex judgments.

 Response: The Company will make every effort to address specifically why its accounting estimates or assumptions bear the
risk of change. The Company will analyze such factors as how it arrived at the estimate, how accurate the estimate has been in the past, how it has changed in the past and where possible whether the estimate will change in the future and disclose
same in its future filings.

 Compensation Policies and Benchmarking, page 41

7.
 Your bulleted disclosure on pages 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 included in your financial plan. In future filings, please disclose all such performance targets. To the extent you believe that disclosure of the targets in not required because it would result in competitive harm such
that the targets could be

 American Vanguard Corporation

 4695 MacArthur Court, Suite 1250, Newport Beach, CA 92660

 4

excluded 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 likely it will be for you to achieve the undisclosed target levels or other
factors. General statements regarding the level of difficulty, or ease, associated with 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 historical bonus practice and the incentive parameters set for the relevant fiscal period.

 Response: We will either disclose the annual performance targets or, if we exclude such targets based upon our belief
that disclosure would result in competitive harm, then we will provide a detailed explanation for such conclusion. Further, we agree to discuss how difficult it would be for named executive officers or the company to achieve undisclosed target
levels. Finally, we agree to provide further insight into factors considered by the committee prior to the awarding of performance-based compensation.

 Item 8 – Financial Statements and Supplementary Date

 Notes to the Financial Statements

 (4) Litigation and Environmental, page 76

8.
Based on your disclosures, it appears that you are subject to significant litigation. Accordingly, we strongly encourage you to consider adding the following disclosure in a tabular
format:

•

 Opening loss contingency amounts,

•

 Increases due to loss contingencies recognized during 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 derecognizing of loss contingencies that are not longer probable,

•

 Decreases for derecognizing of loss contingencies settled, and

•

 Closing loss contingency amounts.

 Response: The comment assumes that we have set up loss contingency in respect of the litigation matters discussed in our reports. As per applicable accounting principles (e.g., FASB Accounting Statement No. 5), we do not set up a
loss reserve for litigation except to the extent that management believes that the loss to the company (either in the way of a judgment or a settlement) is both probable and reasonably estimable. In fact, using this standard, we do not presently
believe that it is appropriate to set up loss contingency reserves for any litigation matter reported in our filing, as we do not believe that a loss is both probable and reasonably estimable in any case. We are willing to make an assertion to that
effect with respect to these litigation matters.

 Further, to the extent that facts and circumstances in any of these cases cause us
to change our opinion and lead us to the conclusion that a loss contingency reserve is appropriate, then we will set up an appropriate reserve. We are dubious, however, about describing any loss

 American Vanguard Corporation

 4695 MacArthur Court, Suite 1250, Newport Be