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June 6, 2023
Maher Al-Haffir
Executive Vice President of Finance and Chief Financial Officer
CEMEX S.A.B. de C.V.
Avenida Ricarda Margáin Zozaya #325
Colonia Valle del Campestre, Garza García
Nuevo León, México 66265
Re:CEMEX S.A.B. de CV
Form 20-F for the Fiscal Year Ended December 31, 2022
File No. 1-14946
Dear Maher Al-Haffir:
            We have limited our review of your filing to the financial statements and related
disclosures 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 20-F for the Fiscal Year Ended December 31, 2022
Risk Factors, page 8
1.We note your disclosure on page 30 that your ability to repay debt and pay dividends
"depends on the continued transfer to it of dividends and other income and funds from its
subsidiaries" and that the ability of your "subsidiaries to pay dividends and make loans
and other transfers to it is generally subject to various regulatory, legal and economic
limitations."  Please explain to us your consideration of the applicability of Rules 4-08(e),
5-04(c) Schedule I and 12-04 of Regulation S-X to your filing.
Our Strategic Priorities, page 57
2.We note that you quantify consolidated EBITDA margin on page 58 without presenting a
comparative IFRS measure with equal or greater prominence and that you have not
reconciled the measure to IFRS.  Please revise future filings to present the IFRS measure
with equal or greater prominence and reconcile the measure to IFRS.  Refer to

 FirstName LastNameMaher Al-Haffir
 Comapany NameCEMEX S.A.B. de C.V.
 June 6, 2023 Page 2
 FirstName LastNameMaher Al-Haffir
CEMEX S.A.B. de C.V.
June 6, 2023
Page 2
Item 10(e)(1)(i) of Regulation S-K and Questions 102.10(a) and 104.04 of the Compliance
and Disclosure Interpretations on Non-GAAP Financial Measures.
Operating and Financial Review and Prospects
Overview, page 148
3.We note that you present a "Continuing operations" revenues line item in the table on
page 149 and a similar line item called "Revenues from continuing operations before
eliminations resulting from consolidation" in the table on page 169.  Considering these
revenue amounts include intracompany revenues, they appear to represent individually
tailored non-IFRS measures.  Accordingly, please remove these line items from future
filings.  Refer to Question 100.04 of the Compliance and Disclosure Interpretations on
Non-GAAP Financial Measures.
Year Ended December 31, 2022 Compared to Year Ended December 31, 2021, page 167
4.We note that your results of operations disclosures predominantly discuss segment
revenues inclusive of intragroup amounts, or "before eliminations resulting from
consolidation."  Considering revenues inclusive of intragroup amounts appear to represent
individually tailored non-IFRS measures pursuant to Question 100.04 of the Compliance
and Disclosure Interpretations on Non-GAAP Financial Measures, please tell us why you
believe it is appropriate to disclose such measures.  Ensure that you revise your
disclosures in future filings to present and discuss segment revenues from external
customers.  To the extent you wish to discuss segment intragroup revenues, consider
providing a separate discussion of such amounts.
5.We note that the second and third sentences of footnote (1) on pages 168, 188, 190, and at
the top of page 170 discuss variations in local currency terms for purposes of a reporting
segment consisting of a region.  Please clarify for us what this statement means and revise
your disclosures accordingly.
Sources and Uses of Cash, page 209
6.Please provide a more informative discussion and analysis of cash flows from operating
activities, including changes in working capital components, for the periods presented.  In
doing so, explain the underlying reasons and implications of material changes between
periods to provide investors with an understanding of trends and variability in cash flows.
Also ensure that your disclosures are not merely a recitation of changes evident from the
financial statements.  Refer to Item 303(a) of Regulation S-K and SEC Release No. 33-
8350.
Notes to the Consolidated Financial Statements
4.2) Discontinued Operations, page F-31
7.We note that you have classified several disposed businesses within discontinued
operations.  Tell us in sufficient detail how the dispositions qualified for discontinued

 FirstName LastNameMaher Al-Haffir
 Comapany NameCEMEX S.A.B. de C.V.
 June 6, 2023 Page 3
 FirstName LastNameMaher Al-Haffir
CEMEX S.A.B. de C.V.
June 6, 2023
Page 3
operations classification pursuant to IFRS 5.32.  In particular, explain how you
determined the disposals represented separate major lines of business or geographical
area.  Per the table on page F-32, we note that revenues of all discontinued operations on a
combined basis were not material to consolidated revenues.
4.3) Selected Financial Information by Reportable Segment and Line of Business, page F-32
8.Although you disclose that your operations are organized in four regions each under the
supervision of a regional president, it appears that the individual countries and combined
"rest of" countries listed in your segment tables represent your reportable segments.
Please revise your disclosures to clearly identify your reportable segments.  Pursuant to
IFRS 8.22(a), also disclose whether operating segments have been aggregated to form any
reportable segments.
9.Please tell us if your chief operating decision maker uses both "Operating EBITDA" and
"Operating earnings before other expenses, net" in assessing segment performance and
deciding how to allocate resources.
10.You disclose on page F-33 that certain countries have been aggregated into a reportable
segment due to "similar regional and economic characteristics and/or materiality."  Please
tell us how your aggregation policy complies with IFRS 8.14, which allows for combining
operating segments that do not meet the quantitative thresholds with others that do not
meet the quantitative thresholds to produce a reportable segment only if the operating
segments have similar economic characteristics and share a majority of the aggregation
criteria in IFRS 8.12.  As currently worded, your disclosure suggests that an immaterial
operating segment may be combined with one that does not share similar economic
characteristics and a majority of the aggregation criteria, or with another immaterial
operating segment, solely due to immateriality.
11.Pursuant to IFRS 8.28, revise your segment tables on pages F-33 and F-34 in future filings
to provide a total for your reportable segments and reconcile such totals to the
corresponding consolidated amounts.  Please note that the "Others" category presented
under IFRS 8.16 should not be included in the reportable segment totals.
12.We note that your tables on pages F-33 and F-34 combine amounts from continuing
operations and discontinued operations, including revenues.  Please note that it generally
is not appropriate to present non-IFRS measures combining the amounts of continuing and
discontinued operations.  Accordingly, confirm that you will refrain from presenting such
non-GAAP measures in future filings.  Refer to Question 100.04 of the Compliance and
Disclosure Interpretations on Non-GAAP Financial Measures.
13.We note that your "Others" category represents a material portion of "Revenue (including
intragroup transactions)."  Pursuant to IFRS 8.16, please disclose the sources of the
revenues included within this category.  In particular, disclose the specific nature of
the intragoup revenues.

 FirstName LastNameMaher Al-Haffir
 Comapany NameCEMEX S.A.B. de C.V.
 June 6, 2023 Page 4
 FirstName LastNameMaher Al-Haffir
CEMEX S.A.B. de C.V.
June 6, 2023
Page 4
16) Goodwill and Intangible Assets, Net, page F-50
14.For cash-generating units ("CGUs") at risk of impairment, such as your United States and
Spain operating segments discussed on page F-55, disclose pursuant to IAS
36.134(f)(i) the amount by which each CGU's recoverable amount exceeds its carrying
amount.
19) Pensions and Post-Employment Benefits, page F-74
15.We note your disclosure on page F-78 that you participate in multiemployer defined
benefit pension plans.  Please tell us and disclose your accounting policy for
multiemployer pension plans.  Also provide the disclosures required by IAS 19.33(b).
Note 21.2) Other Equity Reserves and Subordinated Units, page F-88
16.We note your disclosure on page F-89 that you issued $1 billion of 5.125% subordinated
notes with no fixed maturity date and determined that the notes qualify as equity
instruments under applicable IFRS.  Please tell us in sufficient detail how you determined
the notes should be classified within stockholders' equity.  Within your response, tell us
the business purpose of the arrangement and what benefits, if any, accrue to the
noteholders.
22) Executive Share-Based Compensation, page F-91
17.Please provide all relevant disclosures required by paragraphs 44 through 52 of IFRS 2.  If
you believe certain disclosures are not material for disclosure, please tell us how you
arrived at such determination.
23) Earnings (Loss) Per Share, page F-92
18.We note your disclosure that the number of diluted shares resulting from
your executive stock-based compensation programs is determined using the inverse
treasury method.  Please clarify for us how you calculate diluted shares under the inverse
treasury method.  Also tell us why you do not use the treasury share method and how you
determined the inverse treasury method was appropriate.
            In closing, 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 Charles Eastman at (202) 551-3794 or Andrew Blume at (202) 551-
3254 with any questions.
Sincerely,

 FirstName LastNameMaher Al-Haffir
 Comapany NameCEMEX S.A.B. de C.V.
 June 6, 2023 Page 5
 FirstName LastName
Maher Al-Haffir
CEMEX S.A.B. de C.V.
June 6, 2023
Page 5
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