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April 26, 2022
Shelly M. Chadwick
Chief Financial Officer
Materion Corporation
6070 Parkland Boulevard
Mayfield Heights, Ohio 44124
Re:Materion Corporation
Form 10-K for the Year Ended December 31, 2021
Response dated April 7, 2022
File No. 001-15885
Dear Ms. Chadwick:
            We have reviewed your April 7, 2022 response to our comment letter 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.  Unless we note otherwise, our references to prior comments are to comments in our
March 21, 2022 letter.
Form 10-K for the Year Ended December 31, 2021
Financial Statements
Notes to Consolidated Financial Statements
Note H - Incomes Taxes, page 56
1.We note your response to comment 2.  Since your investment and master supply
agreements appeared to exist in fiscal 2020 and it appears the customer provided
prepayments in fiscal 2020, please clarify for us why there was not an associated deferred
tax asset related to these agreements in the prior year.
Note S - Fair Value Information and Derivative Financial Instruments, page 73
2.We note your response to comment 5.  Please tell us whether the precious metal
consignors have the ability to unilaterally demand return of consigned inventory or

 FirstName LastNameShelly M. Chadwick
 Comapany NameMaterion Corporation
 April 26, 2022 Page 2
 FirstName LastName
Shelly M. Chadwick
Materion Corporation
April 26, 2022
Page 2
terminate the consignment arrangements.  In doing so, tell us the historical frequency of
such returns and terminations and summarize the related contractual terms.  For example,
explain if you have the option to either return the precious metals or deliver cash and, if
so, specify how cash payments are derived.  Also explain if you have the practical ability
to return the consigned precious metals, particularly those that would need to be extracted
from work-in-process or finished goods inventory.  A summary of your manufacturing
and product sale life cycle for consigned inventory would be helpful for our understanding
of these arrangements.  For example, tell us the standard timeframe necessary to convert
consigned raw materials into work-in-process and finished goods and the percentage range
of consigned inventory held as raw material versus work-in-process and finished goods
during the historical periods presented.
            You may contact Heather Clark at 202-551-3624 or Andrew Blume at 202-551-3254 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing