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CORRESP

 July 10, 2023

VIA EDGAR

 Securities and Exchange Commission

Division of Corporation Finance

 100 F Street, N.E.

Washington, D.C. 20549

 Attention: Mr. Charles Eastman and
Mr. Andrew Blume

RE:
 Cemex, S.A.B. de C.V.

Form 20-F for the year ended December 31, 2022

File No. 1-14946

Ladies and Gentlemen:

 On behalf of Cemex,
S.A.B. de C.V. (“Cemex,” the “Company,” “we,” “us” or “our”), this letter provides responses to the comment letter from the staff (the “Staff”) of the Securities and Exchange Commission
(the “Commission”) to Mr. Maher Al-Haffar, Executive Vice President of Finance and Chief Financial Officer of the Company, dated June 6, 2023 (the “Comment Letter”), in connection
with the Company‘s annual report on Form 20-F for the year ended December 31, 2022 (the “2022 20-F”), filed with the Commission on April 28,
2023. The Company‘s responses to the comments raised by the Staff in the Comment Letter are set forth below. For the convenience of the Staff, we have repeated each of the Staff‘s comments in bold type before the corresponding response.
Unless otherwise indicated, capitalized terms used herein have the meanings assigned to them in the 2022 20-F.

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.

RESPONSE: We respectfully acknowledge the Staff’s comment and advise the Staff that we have considered the applicability of Rules 4-08(e), 5-04(c) Schedule I and 12-04 of Regulation S-X to the 2022 20-F. With respect to Rule 4-08(e)(3), we confirm our belief that we have disclosed, to the extent material, the extent and nature of restrictions on the ability of
our subsidiaries to transfer funds to Cemex, S.A.B. de C.V.

 The ability of our subsidiaries to pay dividends and make other transfers to Cemex, S.A.B. de
C.V. is subject to various regulatory, legal and economic limitations of the countries in which we operate. For example, pursuant to applicable Mexican law, dividends from our Mexican subsidiaries are limited to the total profits of each subsidiary
(as reflected in their respective year-end financial statements), after deducting a legally required reserve (equal to one fifth of such subsidiary’s capital) and any losses incurred by such
subsidiary in previous fiscal years and require the approval of its stockholders. Pursuant to applicable Spanish law, our Spanish subsidiaries may only distribute

 Ave. Ricardo Margáin
Zozaya No. 325, Colonia Valle del Campestre, San Pedro Garza García, N.L, 66265 México

 Tel.: +52 (81) 8888-8888

www.cemex.com

 Securities and Exchange Commission

 July 10,
2023

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dividends if, as a result of the distribution, the net worth value of such subsidiary will not be less than such subsidiary’s share capital during the applicable fiscal year and the amount
of the subsidiary’s available reserves is at least equal to the amount of the research and development expenses recorded in by the subsidiary in its financial statements. As a result, each Spanish subsidiary must reserve 10% of its profits in a
given year, until reaching at least 20% of the company’s share capital, and any surplus may then be distributed as dividends. Pursuant to applicable French law, dividends from our French subsidiaries are limited to the net profits of each
subsidiary (as reflected in its year-end financial statements), after deducting a legally required reserve (equal to 10% of such subsidiary’s share capital) and require the approval of its stockholders.

 In addition, because not all of our subsidiaries are wholly-owned, any decision to have any of our subsidiaries declare and pay dividends or make loans
or other transfers to other subsidiaries of Cemex, S.A.B. de C.V. is subject to different regulatory and governance formalities. Such minority-owned subsidiaries, which Cemex, S.A.B. de C.V. only has an indirect ownership stake in, include Cemex
Holdings Philippines, Inc., Trinidad Cement Limited and Caribbean Cement Company Limited, all of which are publicly listed companies.

 After reviewing the
applicable contractual, regulatory, legal and economic restrictions, we do not expect that any restrictions on our existing direct and indirect subsidiaries’ ability to pay dividends and make loans and other transfers to Cemex, S.A.B. de C.V.
will materially affect our ability to meet our cash obligations and pay dividends.

 We advise the Staff that we will revise future filings to include the
foregoing more fulsome disclosure in the risk factors.

 In addition, we advise the Staff that the ratio of the restricted net assets of our consolidated
subsidiaries to our total consolidated net assets as of December 31, 2022 was less than 25%. As a result, we determined that we were not required to provide Rules 5-04(c) Schedule I and 12-04 of Regulation S-X financial statement disclosures.

 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. 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.

RESPONSE: We respectfully acknowledge the Staff’s comment and agree with the Staff that we referenced Cemex’s “Operating EBITDA”
and “Operating EBITDA margin” in our discussion of “Our Strategic Priorities” on page 58 of the 2022 20-F without presenting a comparative IFRS measure with equal or greater prominence and
that we did not reconcile the measure to IFRS. We discuss that information later in “Item 5, Operating and Financial Review and Prospects” of the 2022 20-F.

To address the Staff’s comment, we propose improvements in future filings by including additional disclosure whenever we discuss Operating EBITDA or
Operating EBITDA margin in “Our Strategic Priorities” section. Such additional disclosure would: (a) include definitions of “Operating EBITDA” and “Operating EBITDA margin,” (b) discuss the reasons why those are
relevant measures for management, (c) include a comparative IFRS measure with equal or greater prominence, (d) include a reconciliation of the measure to IFRS, when applicable, and (e) include a cross-reference to the table of Item 5,
Operating and Financial Review and Prospects. Below is an illustrative example of the revised disclosure that we propose to include in future filings, with such new or modified disclosure in underlined text.

 Ave. Ricardo Margáin
Zozaya No. 325, Colonia Valle del Campestre, San Pedro Garza García, N.L, 66265 México

 Tel.: +52 (81) 8888-8888

www.cemex.com

 Securities and Exchange Commission

 July 10,
2023

  Page
 3

 STRATEGIC PRIORITIES. To achieve our mission, our strategy is to create value by building and managing
a global portfolio of integrated cement, ready-mix concrete, aggregates and Urbanization Solutions businesses. Our five strategic priorities, in no particular order, are (i) Health and Safety,
(ii) Customer Centricity, (iii) Innovation, (iv) Sustainability and (v) Operating EBITDA Growth.

 Our Operating EBITDA equals Operating
earnings before other expenses, net plus depreciation and amortization, as reported in our financial statements included elsewhere in this annual report. Our Operating EBITDA margin is calculated by dividing our Operating EBITDA for the period by
our revenues as reported in our financial statements included elsewhere in this annual report. Although Operating EBITDA and Operating EBITDA margin is not a measure of financial performance, an alternative to cash flows or a measure of liquidity
under IFRS, it is the most relevant financial measure used by Cemex’s management to review operating performance and for decision-making purposes, as well as an indicator used by Cemex’s creditors of its ability to internally fund capital
expenditures and to measure its ability to service or incur debt under its financing agreements. Moreover, our Operating EBITDA may not be comparable to other similarly titled measures of other companies. For a reconciliation of Operating EBITDA to
Operating Earnings Before Other Expenses, Net, see “Item 5—Operating and Financial Review and Prospects—Key Components of Results of Operations—Year Ended December 31, 2022 Compared to Year Ended December 31,
2021.”

 During 2022, we made progress on our “Operation Resilience” targets mainly by achieving (i) a consolidated Operating
EBITDA margin of 17.2%, despite rising inflation; (ii) $600 million of closed asset sales, which includes our divestments in Costa Rica and El Salvador, as well as a controlling interest in Neoris, and additional fixed assets; (iii) growth
investments of $474 million on strategic capital expenditures during 2022, which include bolt-on acquisitions in different geographies like Germany, Spain and Texas; (iv) leverage of 2.84x, reaching
two years in a row with a leverage ratio below our initial objective, with a total debt plus other financial obligations reduction of $332 million during 2022; and (v) as of December 31, 2022, a reduction in CO2 emissions of 30% compared to our 1990 baseline. As a result of the progress made, in addition to our previously existing “Operation Resilience” targets not yet achieved, we now look, as
part of our strategic priorities, to maintain our investment grade capital structure and ultimately regain an investment grade rating, and also replaced our previously existing 2030 target to reduce our cement CO2 emissions by 35% compared to our 1990 baseline with a more ambitious 47% reduction goal. For a reconciliation of Operating EBITDA to Operating Earnings Before Other Expenses, Net, see
“Item 5—Operating and Financial Review and Prospects—Key Components of Results of Operations—Year Ended December 31, 2022 Compared to Year Ended December 31, 2021.”

 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.

 RESPONSE: We respectfully acknowledge the Staff’s
comment and advise the Staff that, we do not believe including revenues by reportable segment both before and after eliminations from consolidation to be tailored non-IFRS measures. We believe that paragraph
23 of IFRS 8 permits the inclusion of both revenues from external customers as well as revenues from transactions with other operating segments of the same entity in total revenues for qualifying reportable segments. In addition, according to the
quantitative thresholds in item (a) paragraph 13 of IFRS 8, the 10%

 Ave. Ricardo Margáin
Zozaya No. 325, Colonia Valle del Campestre, San Pedro Garza García, N.L, 66265 México

 Tel.: +52 (81) 8888-8888

www.cemex.com

 Securities and Exchange Commission

 July 10,
2023

  Page
 4

or more revenue limit shall be measured considering both the internal and external revenues of all operating segments. Furthermore, we respectfully advise the Staff that our combined revenues
before eliminations resulting from consolidation are measured in accordance with IFRS 15 and no adjustments are made to those amounts (as would be the case with non-IFRS measures).

Considering the Staff’s comment, we believe that the four line items after the percentage variances including absolute amounts (i.e., (i) continuing
operations, (ii) assets held for sale, (iii) eliminations and (iv) consolidated information) are not necessary in the table on page 149 of the 2022 20-F. Accordingly, we plan to delete such four
line items in our future filings.

 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.

RESPONSE: We respectfully acknowledge the Staff’s comment and advise the Staff that in addition to our response to comment 3 above, our discussion
of revenues by segment in the review of operations has always been made before eliminations for those reportable segments with export sales to other reportable segments. We believe this allows readers to evaluate the total revenues of each such
segment on a stand-alone basis. Usually, any surplus of installed capacity existing in an operating segment gives rise to the opportunity for exports to another operating segments to the extent there is available infrastructure for exports, such as
maritime or land terminals, and if it is economically feasible. Not all countries in which we operate have available infrastructure for exports, and in some cases, it is not economically feasible to provide construct exports infrastructure for
exports due to transportation costs, among other factors. Generally, for those reportable segments with exports infrastructure, export sales increase when local markets are weak, and in some cases, even when local markets are stronger, such
reportable segments still have significant surplus installed capacity. When local markets significantly absorb installed capacity, there is not much incentive for exports which involve lower profitability as compared to local revenues. For instance,
due to excess capacity, we currently have an entire cement plant in Northwest Mexico solely devoted to export sales to our U.S. segment due to the shortage of cement in the United States. We believe that eliminating those intragroup sales from the
continuing operations revenue in Mexico’s reportable segment would not reflect the reality of the segment’s utilization of assets on a stand-alone basis. We believe this information meets our stakeholders’ expectations and provides
them with more useful information when analyzing each segment and generating revenue forecasts on a stand-alone basis.

 Nonetheless, to address the
Staff’s comment we propose revising our future filings to (a) include an additional table of revenues by reportable segment before and after eliminations resulting from consolidation during the reported periods as a preamble to the current
table on page 149 of the 2022 20-F and (b) revise our discussion of results beginning on page 167 of the 2022 20-F to separately discuss segment intragroup revenues
where applicable. We also plan to rename the “Others” line item to be “Other activities” in future filings, which we have reflected in