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October 7, 2022

 Mr. Joseph Klinko, Staff Accountant  	VIA EDGAR

Mr. Karl Hiller, Branch Chief

Division of Corporation Finance

Office of Energy & Transportation

U.S. Securities and Exchange Commission

Washington D.C. 20549

Phone: (202) 551-3824

 Re:   Vertex Energy Inc.

Form 10-K for the Fiscal Year ended December
31, 2021

Filed March 14, 2022

File No. 001-11476

Dear Mr. Klinko and Mr. Hiller:

On behalf of Vertex Energy, Inc.,
a Nevada corporation (the “Company”), I confirm receipt of the comment letter received by the Company from the staff
of the Securities and Exchange Commission (the “Staff” and the “Commission”), dated September 22,
2022 (the “Letter”), relating to the above referenced Annual Report on Form 10-K (the “Annual Report”).

The Company’s responses
to the Staff’s comments set forth in the Letter are indicated below, directly following a restatement of each comment in bold type.

Form 10-K for the Fiscal Year ended December 31, 2021

Business, page 7

1.        We
note that you have provided many details under this heading although have not included individual page numbers within the Business section
such that the entire section is associated with a single page, and that both the Business and Risk Factor sections are associated with
a single page in your Table of Contents. Please utilize page numbers where generally appropriate or conducive to navigation through and
comprehension of the disclosures that you provide.

RESPONSE:

We acknowledge the
Staff’s comment and confirm that we will utilize page numbers in our future filings with the Commission where applicable. We
believe the lack of page numbering in the section entitled “Business” in the Annual Report was due to an issue with the
Edgar conversion process and moving forward we will ensure that all page numbers are included. Furthermore, we will update our Table
of Contents sections as appropriate to accurately reflect the page numbering of referenced section headings.

Management's Discussion and Analysis of Financial Condition and Results
of Operations

Results of Operations, page 60

2.        We
note that your discussion and analysis does not appear to extend to any particular aspects of the UMO Business that you are reporting
as discontinued operations, other than your reference to the associated net income on page 60. Given the termination of your sale agreement
in January 2022, it would appear that further discussion and analysis of its operations should be provided in advance of securing an alternative
sale.

Please also expand the discussion
and analysis in your subsequent interim reports to include quantification of volumes managed or processed by your operating segments,
effects attributed to your recently acquired refinery operations, and differentiation between changes in revenues attributable to volumes
and prices.

RESPONSE:

We acknowledge the Staff’s
comment and confirm that in our subsequent interim reports, we will include a further discussion and analysis of the operations of the
UMO Business that we report as discontinued operations to clarify the particular aspects of the UMO Business which we refer to as discontinued
operations [see also the response to Comment 6, below], and will separately include (1) quantification of volumes managed or processed
by our operating segments, (2) the effects attributed to our recently acquired refinery operations, and (3) differentiation between changes
in revenues attributable to volumes and prices.

Financial Statements

Note 12 - Earnings Per Share, page F-43

3.        Please
address the requirement to provide a reconciliation of the numerators and the denominators of the basic and diluted per share computations
for income from continuing operations as prescribed by FASB ASC 260-10-50-1.

RESPONSE:

We acknowledge the Staff’s
comment and confirm that we will provide a reconciliation of the numerators and the denominators of the basic and diluted per share computations
for income from continuing operations as prescribed by FASB ASC 260-10-50-1 in the notes to the Company’s future financial statements.
We also note that we provided the reconciliation of the numerators and the denominators of the basic and diluted per share computations
for income from continuing operations for the periods ended March 31, 2022 and June 30, 2022, in our Quarterly Reports on Form 10-Q for
the quarters ended March 31, 2022 and June 30, 2022, respectively, and will continue to do so as necessary. Note also that the Company
was in a net loss position at both December 31, 2021 and 2020 resulting in all securities being classified as antidilutive. Please see
the below from our March 31, 2022 Quarterly Report as an example of the disclosures we will include in future filings and the presentation
of the

information from our Annual Report which has been
updated to include a reconciliation of the numerators and the denominators of the basic and diluted per share computations for income
from continuing operations:

The following is a reconciliation
of the numerator and denominator for basic and diluted earnings per share for the three months ended March 31, 2022 and 2021:

    Three Months Ended March 31,

    2022
    2021

    Basic loss per Share

    Numerator:

    Net loss available to shareholders from continuing operations
    $ (14,961,744 )
    $ (3,373,859 )

    Net income available to shareholders from discontinued operations, net of tax
      9,992,889
      4,008,891

    Net income (loss) available to common shareholders
    $ (4,968,855 )
    $ 635,032

    Denominator:

    Weighted-average common shares outstanding
      63,372,005
      47,709,450

    Continuing operations
    $ (0.24 )
    $ (0.07 )

    Discontinued operations, net of tax
    $ 0.16
    $ 0.08

    Basic earnings (loss) per share
    $ (0.08 )
    $ 0.01

    Diluted Earnings per Share

    Numerator:

    Net loss available to shareholders from continuing operations
    $ (14,961,744 )
    $ (3,373,859 )

    Net income available to shareholders from discontinued operations, net of tax
      9,992,889
      4,008,891

    Net income (loss) available to common shareholders
    $ (4,968,855 )
    $ 635,032

    Denominator:

    Weighted-average shares outstanding
      63,372,005
      47,709,450

    Effect of dilutive securities

    Stock options and warrants
      —
      876,886

    Preferred stock
      —
      419,859

    Diluted weighted-average shares outstanding
      63,372,005
      49,006,195

    Continuing operations
    $ (0.24 )
    $ (0.07 )

    Discontinued operations, net of tax
    $ 0.16
    $ 0.08

    Diluted earnings (loss) per share
    $ (0.08 )
    $ 0.01

The following is a reconciliation
of the numerator and denominator for basic and diluted earnings per share for the years ended December 31, 2022, 2021 and 2020:

    For the Years Ended December 31,

    2022
    2021
    2020

    Basic loss per Share

    Numerator:

    Net loss available to shareholders from continuing operations
    $ (32,852,867 )
    $ (25,133,771 )
    $ (11,855,611 )

    Net income available to shareholders from discontinued operations, net of tax
      12,247,610
      (5,628,493 )
      409,983

    Net income (loss) available to common shareholders
    $ (20,605,257 )
    $ (30,762,264 )
    $ (11,445,628 )

    Denominator:

    Weighted-average common shares outstanding
      56,302,716
      45,509,470
      40,988,946

    Continuing operations
    $ (0.58 )
    $ (0.55 )
    $ (0.29 )

    Discontinued operations, net of tax
    $ 0.22
    $ (0.12 )
    $ 0.01

    Basic earnings (loss) per share
    $ (0.36 )
    $ (0.67 )
    $ (0.28 )

    Diluted Earnings per Share

    Numerator:

    Net loss available to shareholders from continuing operations
    $ (32,852,867 )
    $ (25,133,771 )
    $ (11,855,611 )

    Net income available to shareholders from discontinued operations, net of tax
      12,247,610
      (5,628,493 )
      409,983

    Net income (loss) available to common shareholders
    $ (20,605,257 )
    $ (30,762,264 )
    $ (11,445,628 )

    Denominator:

    Weighted-average shares outstanding
      56,302,716
      45,509,470
      40,988,946

    Effect of dilutive securities

    Stock options and warrants
      —
      —
      —

    Preferred stock
      —
      —
      —

    Diluted weighted-average shares outstanding
      56,302,716
      45,509,470
      40,988,946

    Continuing operations
    $ (0.58 )
    $ (0.55 )
    $ (0.29 )

    Discontinued operations, net of tax
    $ 0.22
    $ (0.12 )
    $ 0.01

    Diluted earnings (loss) per share
    $ (0.36 )
    $ (0.67 )
    $ (0.28 )

Note 17 - Segment Reporting, page F-49

4.        We
note that you have maintained your description of products sold by the Black Oil operating segment, as reported in prior years, with no
apparent change to reflect your planned sale of the UMO Business, which you have reclassified as discontinued operations. However, you
previously reported significant sales for the Black Oil segment including base oil, industrial fuel, other re-refinery products, and VGO/marine
fuel sales, all of which are now shown in your report to be zero. Please revise your disclosures as necessary to address the change in
segment composition and to provide the information prescribed by FASB ASC 280-10-50-21, including the specific factors used to identify
your reportable segments, the basis of organization, and an indication of whether operating segments have been aggregated.

RESPONSE:

We will continue to use portions
of our current Black Oil segment after the potential sale of our UMO Business. Specifically, the re-refining complex located in Belle
Chasse, Louisiana, which we refer to as our Myrtle Grove Facility is in the Black Oil segment and is part of our continuing operations.
Additionally, starting in 2022, a new division, “Marine”, has been established and is also included in our Black Oil segment.
In addition, we included corporate selling, general and administrative (SG&A) expenses in the Black Oil segment, which is consistent
with previous year presentations.

Below are revisions (marked in
bold and underline) to our prior introductory disclosures under “Note 17 - Segment Reporting”, to address the planned
sale of the UMO Business, which we have reclassified as discontinued operations.

“The Company’s reportable segments
include the (1) Black Oil, (2) Refining and Marketing, and (3) Recovery segments.

(1) The Black Oil segment continued
operations consist primarily of the sale of (a) other re-refinery products, recovered products, and used motor oil; (b) specialty blending
and packaging of lubricants, (c) transportation revenues; and (d) the sale of VGO (vacuum gas oil)/marine fuel and the Black Oil segment
discontinued operations include the sale of (a) petroleum products which include base oil and industrial fuels—which consist
of used motor oils, cutterstock and fuel oil generated by our facilities; (b) oil collection services—which consist of used oil
sales, burner fuel sales, antifreeze sales and service charges; (c) the sale of other re-refinery products including asphalt, condensate,
recovered products, and used motor oil; (d) transportation revenues; and (e) the sale of VGO (vacuum gas oil)/marine fuel.

(2) The Refining and Marketing segment consists
primarily of the sale of pygas; industrial fuels, which are produced at a third-party facility; and distillates.

(3) The Recovery segment consists primarily
of revenues generated from the sale of ferrous and non-ferrous recyclable Metal(s) products that are recovered from manufacturing and
consumption. It also includes revenues generated from trading/marketing of Group III Base Oils.

We also disaggregate our revenue by product
category for each of our segments, as we believe such disaggregation helps depict how our revenue and cash flows are affected by economic
factors.”

We plan to provide disclosures
similar to the above in future periodic filings.

Additionally, with the recent
acquisition during the second quarter of the Mobile Refinery, our segment reporting and analysis will be enhanced around this asset. We
are currently working to address the change in segment composition and determine the best way to provide the information prescribed by
FASB ASC 280-10-50-21, including the specific factors used to identify our reportable segments, the basis of organization, and an indication
of whether operating segments have been aggregated, which we expect to be completed in the first quarter of 2023.

Note 19 - Discontinued Operations, page F-52

5.        We
note that you began reporting the UMO Business as discontinued operations when filing your interim report for the quarter ended September
30, 2021, and that although the agreement was terminated on January 25, 2022 without a sale, you continue to report the UMO Business as
discontinued operations.

Under FASB ASC 205-20-45-1F,
you would ordinarily need to reclassify the UMO Business as held and used if you no longer meet the criteria in 45-1E, although it appears
you would consider whether an exception to the time period would be available under 45-1G(c), while otherwise meeting the criteria in
45-1E.

Tell us how you have considered
this criteria subsequent to the termination. For example, given that you had sought shareholder approval for the original plan of sale,
please clarify whether you would not also need to obtain shareholder approval for a new plan of sale prior to meeting the criteria in
FASB ASC 205-20-45-1E(a).

Please describe your efforts
to sell the UMO Business subsequent to the termination, with details sufficient to understand how you would fairly characterize the UMO
Business as “being actively marketed at a price that is reasonable given the change in circumstances,” with reference to the
previously contemplated terms of sale, clarifying how your asking price compares to previous arrangement and fair value of the UMO Business.

Please provide any additional
details that are necessary to show how you have appropriately concluded that sale within one year is probable and that actions required
to complete the plan indicate that it is unlikely that significant changes to the plan will be made or that the plan will be withdrawn,
if this is your view.

RESPONSE:

We acknowledge the Staff’s comment.

In regards to our efforts to
sell the UMO Business subsequent to the termination of the prior sale agreement in January 2022, notwithstanding such termination in
January 2022, we have continued to seek potential sale transactions through a third party investment banking firm which we engaged to
help us complete the divestiture, Houlihan Lokey (“Houlihan”). Houlihan was engaged in March 2022 and has, on our behalf,
since such date, reached out to potential purchasers in an effort to secure a sale of our UMO Business. We have had discussions with
several parties to date and hope to be in a position to enter into a definitive sale agreement in the near term – additionally,
as discussed in further detail below, we no longer believe the sale of our UMO Business would require shareholder approval and as such
expect to be able to move forward with such sale quicker than was previously required. As a result of the ongoing activities and timelines
we believe that we still meet the criteria found in FASB ASC 205-20-45-1E and FASB ASC 205-20-45-1G.

Subsequent to the April 1, 2022
acquisition of the Mobile, Refinery our UMO Business operations no longer consist of ‘all or substantially all’ of our assets
and as such, we have determined that the sale of such operations does not reach a level that would require shareholder approval if sold
under Nevada law. As such, the requirement to obtain shareholder approval for any subsequent sale of the UMO Business is no longer necessary.

6.        We
note that you have numerous disclosures throughout