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CORRESP

 September 15, 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 August 17, 2023 (the “Comment Letter”), in
response to our letter, dated July 10, 2023 (the “Initial Response 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.

 Our Strategic Priorities, page 57

1.
 We note your response to comment 2. Although you have indicated that you will include a comparative IFRS
measure with equal or greater prominence, we note that you have not included a comparative IFRS measure for the operating EBITDA margin percentage quantified in your proposed disclosure revisions. Please identify for us the comparative IFRS measure
for Operating EBITDA margin and confirm that you will revise your disclosures accordingly to comply with prominence guidelines.

RESPONSE: We respectfully acknowledge the Staff’s comment and advise the Staff that Operating Earnings Before Other Expenses, Net is the closest
measure to Operating EBITDA in our statements of operations under IFRS and is the stepping stone in determining our Operating EBITDA by adding back depreciation and amortization. However, we advise the Staff that including “Operating Earnings
Before Other Expenses, Net margin” with equal or greater prominence when discussing Operating EBITDA margin would not reflect the actual measurements management uses to review performance and allocate resources and may be misleading.

Accordingly, we respectfully advise the Staff in future filings that we plan to (i) limit our disclosure of Operating EBITDA and its closest IFRS measure
and (ii) avoid including any reference to Operating EBITDA margin unless we believe helpful in the specific context. We refer the Staff to our reference to Operating EBITDA margin in “Our Strategic Priorities” on page 58 of the 2022 20-F, which we included to provide our stakeholders the relevant internal metrics used by our chief executive officer and our other top management to measure performance and profitability and did not include as part

 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

 September
15, 2023

  Page
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 of the financial review of results of operations. Given this context, we believe that presenting the most
comparable IFRS measure with equal or greater prominence would not be helpful and may be misleading to our readers. We advise the Staff that we plan to include a disclaimer that the Operating EBITDA margin is an important profitability and
performance measure for management but is not a measure of operating performance nor is it an alternative to cash flows or a measure of financial position under IFRS. Below is an illustrative example of the revised disclosure for the Strategic
Priorities section beginning on page 57 of the 2022 20-F that we propose to include in future filings, with such new or modified disclosure included in our response to comment 2 in the First Response Letter in
underlined text and any subsequent new or modified disclosure in double underlined text or strikethrough text.

 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 (which
we believe is our Operating EBITDA’s closest measure in our statements of operations under IFRS) 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. We believe there is no
closer IFRS measure for our Operating EBITDA Margin. Our CEO and Executive Committee regularly review our Operating EBITDA margin by reportable segment and on a consolidated basis as a measure of performance and profitability. Although
Operating EBITDA and/or our Operating EBITDA margin are not
measures of operating performance, an alternative to cash flows or a measure of
financial position under IFRS, Operating EBITDA is the financial measure used by Cemex’s management to review operating performance and
profitability, for decision-making purposes and to allocate
resources. Moreover, our “Operating EBITDA is a measure used by Cemex’s creditors
to review our ability to internally fund capital expenditures, to measure its ability to service or incur debt
and comply with financial covenants under our financing agreements. 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.”

 Implemented in 2018, our action
plan “A Stronger Cemex,” was a transformational plan designed to fortify Cemex’s position as a leading global heavy building materials company, accelerate our path to investment grade, enhance our total shareholder return and generate
long-term value for our stakeholders. Under said plan, Cemex: (i) divested $1.6 billion in assets by the end of 2020; (ii) achieved recurring operational improvements of $230 million by 2020; and (iii) accelerated our path to
investment grade by further deleveraging Cemex by reducing our debt by $3.5 billion by the end of 2020.

 In 2020, we implemented the
“One Cemex” commercial model to improve our customers’ experience through customer centricity, aiming to provide a superior omnichannel experience, everywhere and every time. It was supported by digital platforms and the importance of
minimizing financial risk, with an aim to maintain ample liquidity. In 2020, we developed “Operation Resilience,” our medium-term strategy for the following three years, a decisive action plan designed to maximize shareholder value and
reposition us for higher Operating EBITDA growth on a risk-adjusted basis. “Operation Resilience” was not only about deleveraging but also about building a lower risk and faster growing business. Initially, “Operation Resilience”
was aimed at (i) growing the profitability of our business to achieve a consolidated Operating EBITDA margin equal to or

 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

 September
15, 2023

  Page
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 greater than 20% by 2023, considering our then current
portfolio, which management believes is a reasonable level of profitability, despite Operating EBITDA margin not being a measure
of operating performance, an alternative to cash flows or a measure of financial position under IFRS,
through cost reduction measures and other commercial and operational initiatives; (ii) optimizing our portfolio for Operating EBITDA growth through the execution of strategic divestments and reinvestments, thereby constructing a portfolio more
weighted towards the United States and Europe, after which we expect we will be a heavy building materials company with a large part of its footprint represented by the United States, Europe and Mexico, focusing on vertically integrated positions
near growing metropolises and developing Urbanization Solutions as one of our four core businesses; (iii) de-risking our capital structure, reducing our cost of funding and ultimately achieving investment
grade capital structure by targeting additional net debt paydowns and a leverage target equal to or below 3.0x for December 2023, among other initiatives, including extending our debt maturity profile, minimizing our cost of funding and raising
funds in local currency to better align our Operating EBITDA and debt; and (iv) leveraging sustainability and digital platforms as a competitive advantage by moving forward on achieving our 2030 target to reduce our cement CO2 emissions by 35%
compared to our 1990 baseline and our ambition to deliver net-zero CO2 concrete by 2050.

 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 (our Operating
EBITDA margin is not a measure of operating or financial performance, an alternative to cash flows or a measure of liquidity under IFRS); (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, attributable to our increase in Operating EBITDA in 2022 as compared to
2021 leading to a solid 21% Operating EBITDA growth in our Urbanization Solutions core business; (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.”

 During 2022, we repaid or
refinanced $1.9 billion of debt, and by applying free cash flow and proceeds from asset sales, we reduced consolidated net debt, as defined in the Credit Agreements, by $300 million. Also during 2022, we reduced interest expenses by
$45 million, or 8% compared to 2021. Most importantly, we increased the leverage ratio, as calculated under the Credit Agreements, by 0.11x to 2.84x.

In addition, to further fortify our balance sheet, we continue to be focused mainly on the following three initiatives, while at all times
remaining committed to building a better world and helping alleviate some of the biggest challenges communities are facing today: (i) growing our Operating EBITDA through further cost- reduction efforts, operating efficiencies, customer-centric
commercial strategies across all our core businesses and strategic growth investments; (ii) maximizing our free cash flow, which is expected to be used mainly for debt reduction and our bolt-on
investments; and (iii) continuing to execute selective accretive divestments by selling what we believe are non-essential assets, which could allow us to free up more free cash flow.

 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

 September
15, 2023

  Page
 4

 Operating and Financial Review and Prospects

2.
 We have reviewed and are still evaluating your responses to comments 3 and 4. Please provide us with any
pertinent additional information regarding your presentation and discussion of external customer and intragroup revenues.

RESPONSE: We respectfully acknowledge the Staff’s comment and advise the Staff that in addition to our proposed changes outlined in our response
to comments 3 and 4 in the Initial Response Letter, we plan to further improve our disclosure in future filings by presenting our revenues before intragroup transactions and our revenues to external customers in all applicable tables. To address the
Staff’s comment, below is an illustrative example of certain revised paragraphs in our Overview and Results of Operations sections and the several tables regarding our presentation of revenues before and after intragroup transactions on pages
149, 168 and 169 of the 2022 20-F, as well as the discussion of revenues by reportable segment beginning on page 171 of the 2022 20-F and the related equivalent
comparative disclosures of the prior year that we propose to include in future filings, with such new or modified disclosure included in our response to comment 4 in the First Response Letter in underlined text and any subsequent new or modified
disclosure in double underlined text or strikethrough text.

 Overview

Our export sales from one reportable operating segment to another are important to
evaluate the performance, market dynamics and assets’ utilization of each reportable segment on a stand-alone basis. Surplus of installed capacity or attractive export prices existing in a reportable operating segment give 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. Accordingly, the percentage changes in cement sales volumes described in this annual report
for our operations in a particular country or region include the number of tons of cement and/or the number of cubic meters of ready-mix concrete sold to our operations in other countries and regions.
Moreover, unless otherwise indicated, the revenues financial information presented in this annual report for our operations in each country or region includes the Dollar
amounts and percentage variations of the year as compared to the previous year, as applicable, of
both revenues to external customers, which summarizes our consolidated revenues as reported in the financial statements, as well as revenues
including derived from sales of cement and ready-mix concrete to our operations in other countries and regions, which have been
eliminated in the preparation of our audited consolidated financial statements as of and for the year ended December 31, 2022 included elsewhere in this annual report.

The following table sets forth selected financial information of revenues before
intragroup transactions, eliminations resulting from consolidation (export sales from one country to another as described above) and revenues to external customers for each of the three years ended December 31, 2020, 2021 and 2022 by geographic
reportable segment.

Revenues including intragroup
t