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Correspondence

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, N.E.

Washington, DC 20549-4628

 Attn.:  Brad
Skinner, Senior Assistant Chief Accountant

June 15, 2011

RE:

 McCormick & Company, Incorporated (the “Company”)

 Form 10K for Fiscal Year Ended November 30, 2010

 Filed January 27,
2011

 Form 10-Q for Fiscal Quarter Ended February 28, 2011

 Filed April 1, 2011

 Commission File No.: 1-14920

Dear Mr. Skinner:

 Please
find below our responses to the comments raised by the Staff of the Securities and Exchange Commission (the “Commission”) in its letter dated May 11, 2011, with respect to the above-captioned Form 10-K. For ease of reference, we have
reproduced below the full text of the Staff’s comments, each of which is followed by the Company’s response. Capitalized terms not defined in this letter shall have the meanings given to them in the Form 10-K.

Commission Comment:

 Form 10-K for
Fiscal Year Ended November 30, 2010

 Exhibit 13

 Note 16: Business Segments, page 55

1.
In response to prior comment one you indicate that significant effort and cost would be required to accumulate the information necessary to provide disclosure of the
revenue attributable to specialty foods. Please describe for us this effort and cost and explain to us how you determined it was significant. In addition, clarify for us whether the significant effort and cost would be incurred one time as a
start-up cost, or annually.

 McCormick & Company Response:

1.
 Specialty foods is a generic term that we use in describing our business. We introduced this term over five years ago in an effort to describe a wide
range of how we provide flavor to our customers, but have not specifically defined the term. It

does not represent a specifically defined set of products at McCormick, and is not used in any internal reporting. In addition, specialty foods is not a term generally used in the packaged food
industry and accordingly would not be relevant or well understood by our investors. Our investor relations department confirms that it has not been asked about, nor has it discussed, specialty foods as a separate product line or category.
Accordingly, we do not believe disclosures around specialty foods would be relevant or well understood by our investors. For these reasons, we do not believe that disclosure about specialty foods, as contemplated by ASC 280-10-50-40 would be
required.

 If we were to craft such a disclosure it would result in a project where we would review our more
than 20,000 different finished goods SKUs to see if they fit into a category that is not currently defined internally or externally. In addition, all of our products are common in that they deliver flavor and specialty foods is not different in this
respect.

 The effort and cost to accumulate information on revenues attributable to specialty foods is outlined below:

1.
As stated above we would first need to define what would be considered in a specialty food category. This term is not defined internally within McCormick, as we do not
manage our business in this way and specialty foods has no definition in the package food industry that we have found. We, of course, could create a definition of specialty foods, however, we do not believe this would be a meaningful disclosure to
our investors.

2.
We would need to then evaluate our more than 20,000 finished goods SKUs to determine if a SKU meets the definition. We would need to go down to the SKU level as none of
our units around the world use specialty foods in their unit reporting. To accomplish this, definitions would be distributed to our units and they would need to manually evaluate their SKUs to determine which would fit the definition of specialty
foods we created. This would be a very time consuming (and costly) task as there would need to be cross-functional teams assembled to parse through this information at multiple locations globally. This is because we do not have a centralized
marketing, sales or finance team that would know our worldwide products.

3.
Once a SKU list was assembled at each location specific programs would need to be written to extract the gross sales information from our systems. We expect this would
be a medium difficulty task as we have many of our units on SAP systems, however, on different versions.

4.
 Next we would assign discounts to each SKU gross sales amount to arrive at net sales. This would be a very significant systems project. In our consumer
segment, as with most consumer goods companies, sales discounts and allowances are a significant part of the business. Our go-to-market strategy

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involves discounts and allowances both by customers and by products. In addition, there are different discounts for different products and the discounts vary from region to region around the
globe. We currently do not have systems that assign discounts and allowances to the SKU level and given the complexity of our go-to-market strategy feel that the cost would be quite significant. We have not done a formal assessment of the systems
cost to assign discounts to a SKU level however we estimate that it would be $5 to $10 million for our major SAP systems and $2 to $5 million for our units not on SAP.

5.
We would then need to accumulate the information from our global units to form a consolidated disclosure. This would be a medium difficulty task.

6.
Since this is a very manual process, and does not conform to existing information requirements for the company, we would need to design and test new controls around the
gathering of this information for disclosure. This would be a medium to high difficulty task depending on the outcome of 4 above.

 Steps 1 and 3 would be more one time in nature, step 4 would require significant upfront costs and then ongoing maintenance and update costs and steps 2 (continual evaluation of new SKUs), 5 and 6 would
be ongoing costs.

 Based on the staff comments it appears we may have created the impression that we have a defined class of
products called specialty foods in our business description disclosure. An investor may also have that same impression. To eliminate any possible misinterpretation of our disclosure, we will delete the term specialty foods from our business
description in our future filings.

 COMMISSION COMMENT:

2.
We have considered your response to prior comment three and the accompanying materials. Please explain to us how you have considered:

•

 Whether each of the ten components identified in your “blue sheets” (e.g., EMEA Consumer, Canada Consumer, etc.) represent distinct operating
segments, under ASC 280-10-50-1. In this regard, it appears that your CODM regularly reviews discrete financial information for these components, and your planning and budgeting process appears to provide disaggregated information for each component
to your CODM for resource allocation purposes.

•

 ASC 280-10-50-8 and the fact that there are segment managers for the ten individual components and no one is held responsible for total consumer and
total industrial.

 Please provide any additional analysis necessary to support your determination of
operating segments. If you ultimately determine that the ten individual components

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are operating segments, provide us a comprehensive analysis of your determination of reportable segments under ASC 280-10-50-10 through 50-19, including supporting calculations for any compound
annual growth rate amounts utilized as part of ASC 280-10-50-11. If necessary, please reevaluate your determination of reporting units under ASC 350-20-35-23 through 35-46.

 McCormick & Company Response:

 As noted in your letter dated May 11, 2011, we
do not currently have individuals who are 100% responsible for the global consumer segment or the global industrial segment. We have managers that we consider constructive segment managers in that they manage the majority of our global Consumer and
Industrial businesses. In addition, we have specifically considered the following facts in our conclusion that we have two operating segments (Consumer and Industrial):

•

 The ten operating components in our blue sheets do not have segment managers who are directly accountable to and maintain regular contact with the CODM
to discuss operating activities, financial results, forecasts, and plans;

•

 The summarized information on the ten operating components in our blue sheets does not include certain expenses that are critical to the operation of
each of the geographic locations, and is thus not at a sufficient level to make resource allocation decisions and the CODM does not allocate resources based on the ten operating components;

•

 Our current organization structure is matrixed between businesses and geography. The nature of our business supports the fact that the more useful
information to investors is by business vs. geography;

•

 Because most of our business is in North America, it’s appropriate to distinguish our business activity by product (Consumer and Industrial) for
segment reporting purposes as a geographic delineation would be less relevant.

 Specifically, in regards to our evaluation
of operating segments, we are providing the following discussion to clarify for the staff our analysis and basis for our conclusions above with respect to our determination of operating segments.

Identification of CODM

 To properly
determine operating segments, the first step is to identify the CODM. In our structure and organization we have one position with the title and responsibilities of the Chairman, President and CEO. There is no other position that has the breadth of
all of the operations of the business reporting to it. We do have a management committee, however, that committee is subordinate to the decisions of the position of Chairman, President and CEO. Accordingly we concluded that Alan Wilson, our
Chairman, President and CEO, is the CODM as contemplated under ASC 280-10-50-5.

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 In this next section we provide information on the nature of our business, our management structure and the
information regularly reviewed by the CODM for allocation of resources. We then summarize how these facts relate to the relevant sections of the accounting literature.

 Nature of our Business

 We operate in two types of businesses globally, Consumer and
Industrial. The Consumer business around the world has the common characteristics of selling similar products under various brand names; it sells to the retail trade either directly or through wholesalers; it has customers that we service globally,
such as Walmart; it carries a higher gross margin; and a significant driver of the business is advertising and promotion. The Industrial business around the world has the common characteristics of selling similar products to food manufacturers and
the foodservice trade; it has a lower margin structure; it has customers that we service globally, including PepsiCo, and it is driven by creating strong relationships with customers by providing flavor solutions through research and development.

 Customer relationships are a significant driver to the Industrial business and we must make strategic decisions about our global customers in
a consistent manner. This is evidenced by the fact that the President, U.S. Industrial Group also has the responsibility for the management of our worldwide strategic industrial customers. In this capacity he will make strategic decisions about our
global customers. For instance, a local geographic general manager may review a business of a major global strategic customer and determine it is not profitable enough to initiate or continue that business. The President, U.S. Industrial Group would
be involved in the decision process and can override the geographic general manager in his/her decision.

 Management Structure

 With respect to our segment conclusions at November 30, 2010, we had three positions with overlapping responsibilities, managing our
businesses around the globe that report to the CODM.

•

 President, U.S. Industrial Group – This position reports directly to the CODM and is primarily responsible for the management of our U.S.
industrial business and our Mexican industrial business (geographic responsibilities), and management of our largest worldwide strategic industrial business customers, including PepsiCo (which are product and customer-specific responsibilities).

•

 President, North American Consumer Foods – This position reports directly to the CODM and is primarily responsible for the management of
our U.S. Consumer Foods Business, our U.S. global export business, our Canadian operations (including both the consumer and industrial operations), and our consumer business in Mexico and other Latin American countries.

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•

 President, International Business – This position reports directly to the CODM and is primarily responsible for all international
operations outside of the Americas (both Consumer and Industrial).

 Below we describe the organization under
each of the three positions above. In this section we have listed only the operating unit responsibilities for each of the three presidents and have not included administrative direct reports such as human resources and finance.

•

 President, U.S. Industrial Group – In addition to responsibility for the U.S. industrial business, other direct reports into this position
include the general manager for our industrial business in Mexico. This position is also responsible for management of our worldwide strategic industrial customers and for this responsibility there is a strong dotted line responsibility to the
industrial businesses at each of our other geographic locations. The combination of direct operating unit responsibility and management of worldwide strategic Industrial segment customers encompasses approximately 85% of the revenue of our Global
Industrial segment.

•

 President, North American Consumer Foods – The direct reports into this position include the general manager of the U.S. consumer business,
the general manager of our Canadian business (which includes both Consumer and Industrial businesses) and the managing director of Hispanic consumer markets (which includes Hispanic consumer products sold in the U.S., our joint venture in Mexico and
our operation in El Salvador that includes both Consumer and Industrial businesses).

•

 President, International Business – The direct reports into this position include the general manager for EMEA (which includes both
Consumer and Industrial businesses), the general manager for China (which includes both Consumer and Industrial businesses) and the general manager for our Asia Pacific Zone (APZ), excluding China (which includes both Consumer and Industrial
businesses).

 Information Used by CODM for Resource Allocation

We provided this information to you in our last response. The information consists of our monthly “blue sheet” reporting package and monthly
reports on operations from various geographic operating locations around the world. The blue sheets display sales and earnings information on the initial pages on a consolidated basis and at a segment (Consumer and Industrial) level. The package
then includes some detailed schedules that help the CODM general understanding of the operating results of the two segments on a geographical basis. The monthly reports on operations are prepared by geographic locations with explanations on a
consolidated basis for that location and then explanations for that location of the Consumer and Industrial businesses. The geographic information included in the blue sheets and reports on operations does not include an

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allocation of certain expenses that are critical to assessing performance and allocating resources (see discussion below). The CODM uses information at a Consumer and Industrial segment level
(pages 1-3, 7, 8 and 10)