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Correspondence

 January 18, 2013

Re:
American Vanguard Corporation

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

 Filed on March 9,
2012

 File No. 001-13795

 On behalf of American Vanguard Corporation, I am responding to your letter dated December 12, 2012 to myself in my capacity as CFO of American Vanguard Corporation, regarding the Commission’s
review of both our Form 10-K for the fiscal year ended December 31, 2011 and our Form 10-Q for the fiscal quarter ended September 30, 2012. In response to the comments raised in your letter, we confirm that we will revise our future
filings as more fully described below. Further, in response to your request for additional information or clarification, we provide the following responses. For your convenience, we have re-presented the Commission’s comments in bold-italicized
font and indicated our answers in non-italics, non-bold.

1.
Please consider revising to provide a description of the manufacturing and distribution of your products.

Company response: The Company will expand its disclosure on Form 10-K for Fiscal Year Ended December 31, 2012 to incorporate a brief
description of its manufacturing and sales logistics processes.

 Manufacturing and Distribution

Through its four domestic manufacturing facilities (see Item 2, Properties), AMVAC synthesizes many of the technical grade active
ingredients that are used in its end-use products. Further, AMVAC formulates and packages the majority of its end use products at its own facilities or at the facilities of specialist formulators. AMVAC distributes its products domestically through
national distribution companies (see “Customers” above) that purchase AMVAC’s goods on a purchase order basis, and, in

 American
Vanguard Corporation, 4695 MacArthur Court, Suite 1250, Newport Beach, CA 92660 ~ (949) 260-1200

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turn, sells them to retailers and/or growers/end-users. The company’s domestic and international distributors typically have long-established relationships with retailers/end-users,
far-reaching logistics and transportation capabilities, and customer service expertise. The markets for AMVAC’s products vary by region, target crop/use and the type of distribution channel, and AMVAC’s customers are expert in addressing
these markets. Internationally, the Company sells products either via its sales offices in the Netherlands, Mexico or Costa Rica, via employed sales force executives located in France, Canada or Venezuela, or via sales agents in other territories.

 2. Please revise your net sales discussion to quantify the effects of price and volume on results. Refer to Item 303(a)
(3) (iii) of Regulation S-K.

 Company Response: The Company sells its products in many different forms, such as
liquids, granules, powders, micro-encapsulated products. These products are sold in either a concentrated, diluted or formulated form. Because of the variety of forms in which our products are sold, a single volume measurement is not a key metric
that we track. However, for the Form 10-K for fiscal year ending December 31, 2012 and all subsequent filings, we will revise our net sales discussion to include additional disclosure indicating, on a product group level, the main drivers of
price increase and, by difference, the drivers related to volume.

 3. We note your discussion and analysis of costs of sales is limited
to the context of gross margin, which does not address your cost of sales directly. We believe your gross margin disclosure should be supplemented with or, preferably, replaced by a discussion and analysis of costs of sales on a stand-alone basis
(not in the context of gross margin). Further, we believe such disclosure should include separate quantification and discussion of changes in significant components of cost of sales that caused costs of sales to materially 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 changes are attributable,
you do not quantify certain of these factors nor analyze the underlying business reasons for the changes. For example, you attribute the change in gross margin, in part, to improved manufacturing activity, but you do not quantify this factor.

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

•

 increasing the use of tables to present dollar and percentage changes in accounts and margin rates, 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; and

•

 ensuring that all material factors are quantified and analyzed.

 American
Vanguard Corporation, 4695 MacArthur Court, Suite 1250, Newport Beach, CA 92660 ~ (949) 260-1200

 2

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

Company Response: We will revise our future filings to comport with the recommendations set forth in your comment letter. We have prepared the
following disclosure based upon our financial results reported for the fiscal year ended December 31, 2011.

Net Sales

2011

2010

Variance

 Insecticides

137,460

84,500

52,960

 Herbicides

90,782

86,780

4,002

 Other

47,175

32,113

15,062

 Crop

275,417

203,393

72,024

 Non Crop

29,012

23,466

5,546

 Total

304,429

226,859

77,570

Cost of Goods

2011

2010

Variance

 Insecticides

(75,771
)

(52,904
)

(22,867
)

 Herbicides

(60,219
)

(54,260
)

(5,959
)

 Other

(29,079
)

(18,312
)

(10,767
)

 Crop

(165,069
)

(125,476
)

(39,593
)

 Non Crop

(16,292
)

(15,062
)

(1,230
)

 Total

(181,361
)

(140,538
)

(40,823
)

 Gross Margin

 Insecticides

61,689

31,596

30,093

 Herbicides

30,563

32,520

(1,957
)

 Other

18,096

13,801

4,295

 Gross Margin Crop

110,348

77,917

32,431

 Gross Margin Non-Crop

12,720

8,404

4,316

 Total Gross Margin

123,068

86,321

36,747

 Gross Margin Crop

40
%

38
%

 Gross Margin Non Crop

44
%

36
%

 Total Gross Margin

40
%

38
%

 Our cost of sales for 2011 was $181,361 or 60% of net sales. This compared to $140,538 or 62% of net sales for 2010. The
decline in cost of sales as a percentage of net sales in 2011 arose primarily from the following factors. In 2011 the Company focused on selling those products having higher margins or lower costs. At the same time, we de-emphasized sales of those
products that are subject to pricing pressure from generic competition (e.g., acephate, bifenthrin and permethrin) which products typically have a high cost of sales as compared to the market selling price. Further, with

 American
Vanguard Corporation, 4695 MacArthur Court, Suite 1250, Newport Beach, CA 92660 ~ (949) 260-1200

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increased demand for plant capacity relating to the production of our own products, we allowed a drop in manufacturing activity for third parties. Typically, such activities enable us to cover
costs but do not generate much, if any, gross profit. As detailed in the table, the change in volume, mix, price and manufacturing activity resulted overall in a 2% improvement in gross margin to 40% in 2011 as compared to 38% for the same period of
the prior year.

 4. We note from your disclosure on page 29 that accrued program costs are a critical accounting policy. However, it is
not apparent from your results of operations disclosure whether accrued program costs had a material impact on results in the years presented. Please advise.

 Company Response: Program costs are material to our financial statements and involve significant estimates by management in the normal course of our financial reporting. If our estimated program
accruals are inaccurate, then our reported program costs (contra-revenue) for a given period could result in significant and unexpected fluctuations in our reported results. Because of this risk, we believe that the program accrual policy is
critical. Historically our program cost estimates have been accurate and consistent in relation to gross sales. Accordingly, program related activities and costs have not fluctuated in a manner causing a material impact to our gross margin that
would require further disclosure.

 American
Vanguard Corporation, 4695 MacArthur Court, Suite 1250, Newport Beach, CA 92660 ~ (949) 260-1200

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 5. Please confirm that your principal executive officer, principal financial officer and principal
accounting officer or controller will sign your Form 10-K in their individual capacities. These signatures should appear in the second signature block of the signature section.

 Company Response: We confirm that the persons holding such positions will sign the Form 10-K in their individual capacities. Below is a draft of the signature block for future Form 10-K filings.

 AMERICAN VANGUARD CORPORATION

(Registrant)

By:

 /S/    ERIC G.
WINTEMUTE

By:

 /S/    DAVID T.
JOHNSON

Eric G. Wintemute

David T. Johnson

 Chief Executive Officer

 and Chairman of the Board

 Chief Financial Officer

 and Principal Accounting Officer

March 1, 2013

March 1, 2013

 Pursuant to the requirements of the Securities Exchange Act of 1934, this report has been signed below by
the following persons on behalf of the Registrant and in the capacities indicated.

By:

 /S/    ERIC G.
WINTEMUTE

By:

 /S/    DAVID T.
JOHNSON

Eric G. Wintemute

David T. Johnson

 Principal Executive Officer

and Chairman of the Board

 Principal Financial Officer

and Principal Accounting Officer

March 1, 2013

March 1, 2013

By:

 /S/    DEBRA
EDWARDS

By:

 /S/    JOHN L.
KILLMER

 Debra Edwards

 Director

 John L. Killmer

 Director

March 1, 2013

March 1, 2013

By:

 /S/    LAWRENCE S.
CLARK

By:

 /S/    CARL R.
SODERLIND

 Lawrence S. Clark

 Director

 Carl R. Soderlind

 Director

March 1, 2013

March 1, 2013

By:

 /S/    IRVING J.
THAU

By:

 /S/    ALFRED
INGULLI

Irving J. Thau

Alfred Ingulli

Director

Director

March 1, 2013

March 1, 2013

By:

 /S/    ESMAIL
ZIRAKPARVAR

By:

 /s/    Jerome
Coben

Esmail Zirakparvar

Jerome Coben

Director

Director

March 1, 2013

March 1, 2013

 American
Vanguard Corporation, 4695 MacArthur Court, Suite 1250, Newport Beach, CA 92660 ~ (949) 260-1200

 5

 6. Based on your disclosure, it appears that intangible assets consist of product rights, customer
lists, and trademarks. Please revise to disclose the gross carrying amount and accumulated amortization by major intangible asset class for each balance sheet date presented. Refer to ASC 350-30-50-2.

Company Response: We will revise our disclosure, as requested, for the Form 10-K for Fiscal Year Ended December 31, 2012 and subsequent
filings. Using information derived from our Form 10-K for the fiscal period ended December 31, 2011, our revised disclosure would be as follows:

2011

2010

Gross

Accumulated
Amortization

Net
Book
Value

Gross

Accumulated
Amortization

Net
Book
Value

 Product Rights

135,901

33,130

102,771

138,591

27,727

110,864

 Customer Lists

1,091

109

982

183

183

 Trademarks

12,941

505

12,436

4,202

4,202

 Total Intangibles

149,933

33,744

116,189

142,976

27,727

115,249

 The primary identifiable intangible assets of the Company relate to product rights and trademarks
associated with its product line acquisitions. Product rights generally consist of product registrations, related technical data and other supporting data filed with the United States Environmental Protection Agency, state regulatory agencies and
other similar agencies in the international territories in which we do business. In December 2010, the Company completed three product line acquisitions and performed valuations designed to identify and value the intangible assets acquired. Results
of 2010 acquisitions were included in the Company’s operations from the dates of the respective acquisitions and pro forma results are not provided since the amounts are not material to the consolidated results of operations.

 American
Vanguard Corporation, 4695 MacArthur Court, Suite 1250, Newport Beach, CA 92660 ~ (949) 260-1200

 6

 7. Your conclusion regarding the effectiveness of disclosures controls and procedures does not state
the entire definition of disclosure controls and procedures as defined in Exchange Act Rules 13a-15(e) and 15d-15(e). Specifically, you did not indicate that disclosure controls and procedures are designed to ensure that information required to be
disclosed in reports filed or submitted under the Act is accumulated and communicated to management as appropriate to allow timely decisions regarding required disclosure. Although there is no requirement to disclose the full definition, specific
reference to only a portion of the definition gives the appearance of limiting management’s conclusion solely to the portion referred to. Please represent to us and please revise future filings to state management’s conclusion in regard to
the company’s disclosure controls and procedures as fully defined in Exchange Act rules 13a-15(e) and 15d-15(e).

 Company
response: We hereby represent as indicated below and will revise our future filings to state management’s conclusion in regard to the company’s disclosure controls and procedures as fully defined in Exchange Act rules 13a-15(e) and
15d-15(e). Our revised conclusion will read as follows:

 Management, under the supervision of the Company’s Chief
Executive Officer and Chief Financial Officer, periodically evaluate the effectiveness of the design and operation of the Company’s disclosure controls and procedures. Based upon this evaluation, the Chief Executive Officer and Chief Financial
Officer have concluded that these disclosure controls and procedures are effective in ensuring that the information required to be disclosed in reports filed under the Securities Exchange Act of 1934 is (i) recorded, processed, summarized and
reported on a timely basis, and (ii) accumulated and communicated to the Company’s management, including the Chief Executive Officer and Chief Financial Officer, as appropriate to allow timely decisions regarding required disclosure.

 In responding to your comments please provide a written statement from the company acknowledging that: 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 federal securities laws of the United States.

Company response: We hereby acknowledge that:

•

 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 to any proceeding initiated by the Commission or any person under the federal securities laws of
the United States.

 American
Vanguard Corporation, 4695 MacArthur Court, Suite 1250, Newport Beach, CA 92660 ~ (949) 260-1200

 7

 Please feel free to contact either me at 949-260-6006 or Timothy Donnelly at 949-221-6115 if you have any
questions or require further clarification on this matter.

 Sincerely,

 /s/ David T. Johnson

 David T. Johnson

 Chief Financial Officer,

 Vice President & Treasurer

American Vanguard Corporation

 American
Vanguard Corporation, 4695 MacArthur Court, Suite 1250, Newport Beach, CA 92660 ~ (949) 260-1200

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