SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
                  WASHINGTON, D.C. 20549

      DIVISION OF
CORPORATION FINANCE

        April 24, 2014

Via E -mail
Alan D. Wilson
Chairman, President & Chief Executive Officer
McCormick & Company, Incorporated
18 Loveton Circle
Sparks, Maryland 21152

 Re: McCormick & Company, Incorporated
  Form 10 -K for the Fiscal Year Ended November 30 , 2013
  Filed January 29 , 2014
  File No. 1 -14920

Dear Mr. Wilson :

  We have limited our review of your filing to your contacts with countries that have  been
identified as state sponsor s of terrorism, an d we have the following comment .  Our review with
respect to this issue does not preclude further review by the Assistant Director group with respect
to other issues.   At this juncture, we are asking you to provide us with information so we may
better understand your disclosure.

  Please respond to this letter within ten business days by providing the requested
information, or by advising us when you will provide the requested response.  If  you do not
believe our comment applies  to your facts and circumstances, please tell us why in your response.

  After reviewing the information you provide in response to this comment , we may have
additional comments.
General
1. You told us in your letter dated March 18,  2011 that you purchased goods from Syria.   In
addition, you state in the Business section and elsewhere that you have operations in
Africa, a region that includes Sudan.   Sudan and Syria are designated as state sponsors of
terrorism by the State Departmen t and are subject to U.S. economic sanctions and export
controls.   Your Form 10 -K does not include disclosure about any contacts with Sudan or
Syria.   Please provide us with information regarding any contacts with Sudan and Syria
since the referenced lette r.  Your response should describe any goods that you have
purchased from, or provided into, Sudan and Syria, directly or indirectly, and any
agreements, arrangements, or other contacts you have had with the governments of Sudan
and Syria or entities they c ontrol.

Alan D. Wilson
McCormick & Company, Incorporated
April 24 , 2014
Page 2

 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 the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.  Since the company and its management are
in possession of all facts relating to the company’s disclosure, they are responsible for the
accuracy and adequacy of the disclosures they have made.

In responding to our 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 the federal securities laws of the United States.

Please contact Pradip Bhaumik, Special Counsel, at (202) 551 -3333 or me at (202) 551 -
3470 if you have any questions about the comment  or our review.

         Sincerely,

         /s/ Cecilia Blye

         Cecilia Blye, Chief
         Office of Global Security Risk

cc:  Roger Schwall
  Assistant Director
 Division of Corporation Finance