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March 9, 2021
Michael R. Smith
Chief Financial Officer
McCormick & Company, Incorporated
24 Schilling Road, Suite 1
Hunt Valley, Maryland 21031
Re:McCormick & Company, Incorporated
Form 10-K for the Fiscal Year Ended November 30, 2020
Filed January 28, 2021
File No. 001-14920
Dear Mr. Smith:
            We have reviewed your filing and have the following comments.  In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.
            Please respond to these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Form 10-K for the Fiscal Year Ended November 30, 2020
Management’s Discussion and Analysis of Financial Condition and Results of Operations
Non-GAAP Financial Measures, page 32
1.We note that Adjusted EBITDA, net debt, and leverage ratio are financial covenants under
your credit agreements.  In future filings, please revise your disclosure to address the
following:

•Describe the material terms of the covenant;
•Indicate the amount or limit required for compliance with the covenant; and
•Disclose the actual or reasonably likely effects of compliance or non-compliance with
the covenant on the company's financial condition and liquidity.

Refer to Question 102.09 of our Compliance & Disclosure Interpretations on Non-GAAP
Financial Measures.

 FirstName LastNameMichael R. Smith
 Comapany NameMcCormick & Company, Incorporated
 March 9, 2021 Page 2
 FirstName LastName
Michael R. Smith
McCormick & Company, Incorporated
March 9, 2021
Page 2
Notes to Consolidated Financial Statements
1. Summary of Significant Accounting Policies - Revenue Recognition, page 61
2.Please revise your discussion in future filings to clarify whether revenue from the majority
of your contracts is recognized at a point in time, or if for certain contracts, revenue is
recognized over time, upon satisfaction of the performance obligation.  We note
disclosure on page 61 that revenue is recognized “when control passes to the customer.”
In this regard, discuss how and when transfer of control of your products occur. Refer to
ASC 606-10-25-24 and 606-10-50-12(a).
            We remind 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.
            You may contact Heather Clark at 202-551-3624 or Martin James, Senior Advisor, at
202-551-3671 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing