SecProbe.io

December 19, 2017
Mail Stop 4631

Via E -mail
Mr. Manuel Bartolome Ferreyros Pena
Chief Financial Officer
Cementos Pacasmayo S.A.A.
Calle La Colonia 150, Urbanizacion El Vivero
Surco, Lima
Peru

Re: Cementos Pacasmayo S.A.A.
 Form 20 -F for Fiscal Year Ended December 31, 2016
Filed April 28, 2017
File No. 1-35401

Dear Mr. Pena :

We have reviewed your filing  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 this letter within ten business days by providing the requested
information, or by advising us when you will provide the requested response.   If you do not
belie ve our comments apply to your facts and circumstances, please tell us why in your response.

After reviewing the information you provide in response to these comments, we may
have additional comments.

Form 20 -F for the period ended December  31, 2016

Note 1 Corporate Information, page F -9

1. In order to better understand your determination that the net assets of Fosfatos del
Pacifico S.A (“Fosfatos”) met the criteria in paragraph 12A of IFRS 5 to be classified as
held for distribution as of De cember 31, 2016, please clarify the facts supporting your
conclusion that the spin -off transaction was expected to result in a loss of control.   We
note from your disclosures on page 16 that you expected to maintain management of
Fosfatos and FOSSAL S.A.A.  (“FOSSAL”) until it was able to retain separate
management and operate independently.  In this regard, please tell us specifically about
the indiv idual owners, indicating ownership percentages, before and after the transaction
that had the power to govern  the financial and operating policies of Fosfatos and
FOSSAL, addressing:

Mr. Pena
Cementos Pacasmayo S.A.A.
December 19, 2017
Page 2

  your retained economic and/or voting interests after the spin -off.  In this regard, we note
your disclosures in Form 6 -K filed as of November 3, 2017 that you received 9,148,373
investment shares in FOSSAL as a result of the spin -off;
 whether you entered into a separate agreement to manage Fostafos and FOSSAL until it
was able to retain separate management and operate independently. To the extent that
such an agreement exists, des cribe the key terms and provisions that addressed the power
to govern the financial and operating policies of Fostafos and FOSSAL; and
 if applicable, the date when Fosfatos del Pacifico and FOSSAL retained separate
management and began operating independen tly.

2. Please tell us if you concluded that the spin -off transaction falls within the scope of
IFRIC 17, and if not, the facts supporting your determination.   If so, please tell us the
date the distribution was no longer at your discretion and how you conte mplated the fact
that approval for this transaction was received in September of 2016 at the General
Shareholders Meeting and whether a liability was recognized for the fair value of the
assets to be distributed.   Also tell us if a profit or loss was recog nized upon settlement;
and, if so, how you measured that amount.

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 Ameen Hamady , Staff Accountant, at (202 ) 551 -3891, or in his
absence,  me at (202) 551 -3355 , if you have questions regarding comments on the financial
statements and related matters.  Please contac t Frank Pigott at (202) 551 -3570 , or in his absence,
Pamela Long, Assis tant Director, at (202) 551 -3765  with any other questions.

Sincerely,

 /s/ Terence O ’Brien

Terence O’ Brien
Accounting Branch Chief
Office of Manufacturing and
Construction