SecProbe.io

March 23, 2017

Via E -mail
Lawrence E. Kurzius
 Chairman and 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 , 2016
  Filed January 25, 2017
  File No. 1 -14920
Dear Mr. Kurzius :
We have limited our review of your filing to your contacts with a country that has  been
identified as a state sponsor  of terrorism, and we have the following comments.  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 informat ion 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 comments apply to yo ur 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 stated in your letter to us dated May 22, 2014 that you purchased good s originating
in Syria, a country that  is designated by the State Department as a state sponsor of
terrorism and is subject to U.S. economic sanctions and export controls.   Your Form 10 -
K does not include disclosure about any contacts with Syria.   Please describe  to us the
nature and extent of your past, current and anticipated contacts with Syria since the
referenced letter, whether through subsidiaries, joint ventures, distributors, vendors or
other direct or indirect arrangements.  You should describe any goods  you have provided
into Syria, directly or indirectly, and any agreements, arrangements or other contacts you
have had with the government of that country or entities it controls.

2. Please discuss for us the materiality  of the contacts with Syria you descri be in response to
the comment above, and whether those contacts constitute a material investment risk for

Lawrence E. Kurzius
McCormick & Company, Incorporated
March 23, 2017
Page 2

 your security holders.  You should address materiality in quantitative terms, including the
approximate dollar amounts of any  associated revenues, ass ets and liabilities for the last
three fiscal years and the subsequent interim period.  Also,  address materiality in terms of
qualitative factors that a reasonable investor would deem important in making an
investment decision, including the potential impa ct of corporate activities upon a
company’s reputation and share value.  As you know, v arious state and municipal
governments, universities and other investors have proposed or adopted divestment or
similar initiatives regarding investment in companies tha t do business with U.S. -
designated state sponsors of terrorism.  Your materiality analysis should address the
potential impact of the investor sentiment evidenced by such actions directed toward
companies that have operations assoc iated with Syria.

We rem ind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.

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

         Sincerely,

         /s/ Cecilia Blye

         Cecilia Blye, Chief
         Office of Global Security Risk

cc:  Roger Schwall
  Assistant Director
 Division of Corporation Finance