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United States securities and exchange commission logo
January 18, 2023
Daniel O'Brien
President and Chief Executive Officer
Flexible Solutions International, Inc.
6001 54 Ave.
Taber, Alberta, Canada
T1G 1X4
Re:Flexible Solutions International, Inc.
Registration Statement on Form S-3
Filed January 6, 2023
File No. 333-269143
Dear Daniel O'Brien:
            We have limited our review of your registration statement to those issues we have
addressed in our 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 this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
Form S-3 filed January 6, 2023
Description of Securities, page 7
1.We note your disclosure on the cover page relating to the offer of convertible preferred
stock, rights, warrants and units, which you otherwise do not mention in the Description
of Securities section.  Please revise to include descriptions of each type of security being
registered in this registration statement.
Exhibits
2.Please revise your fee table to include the units being registered in the registration
statement and also provide information as to each type of securities separately in the
manner required by Item 601(b)(107) of Regulation S-K.

 FirstName LastNameDaniel O'Brien
 Comapany NameFlexible Solutions International, Inc.
 January 18, 2023 Page 2
 FirstName LastName
Daniel O'Brien
Flexible Solutions International, Inc.
January 18, 2023
Page 2
3.We note that your Exhibit 5.1 opinion includes an opinion with respect to various
"securities which are the subject of the Registration Statement," which include shares of
common stock, preferred stock, convertible preferred stock, rights, units and warrants.
Please revise the Exhibit 5.1 opinion to address the legality of each type of security
offered and also disclose that the units will be binding obligations of the company. For
guidance, please consider Section II.B.1.h of Staff Legal Bulletin No. 19.
            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.
            Refer to Rules 460 and 461 regarding requests for acceleration.  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            Please contact Jane Park at 202-551-7439 or Loan Lauren Nguyen at 202-551-3642 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services
cc:       William Hart, Esq.