Acme United Corporation
60 Round Hill Road
Fairfield, CT  06824


March 10, 2006

Nili Shah, Accounting Branch Chief
Securities and Exchange Commission
Washington, D.C. 20549-0404
RE: Acme United Corporation

Dear Ms. Shah:

We have reviewed your response to our letter dated January 31, 2006 as it
relates to SFAS 131 and segment reporting. It has been the Company's position
that although we have operations located in various countries throughout the
world, the operations and products of each segment are so similar, that all
operating segments should be aggregated into one reportable segment. However,
after reviewing your comments and suggestions, we have determined to make
disclosure which includes three reportable segments based on geographic
location. The reportable segments are: 1) United States, 2) Canada and 3)
Europe. The United States includes the results of our operating unit in Asia.

Acme United (Asia Pacific) Limited is involved in sourcing, quality control and
sales activities. The sourcing and quality control activities are service
functions primarily for the U.S. business. The sales activity is related to
direct import sales primarily to U.S. customers. These activities are an
integral part of the Company's U.S. operations. The Company's management and the
Chief Operating Decision Maker view the activities of Asia Pacific as an
extension of the U.S. operations and therefore view the results of these two
operating segments on a consolidated basis. Based on these facts we feel that it
is appropriate to aggregate the United States and Asian operating segments into
one reportable segment.

These modifications will be reflected in the Form 10-K to be filed for the year
ended December 31, 2005.



Sincerely,

/s/ Paul G. Driscoll
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Paul G. Driscoll
Vice President and Chief Financial Officer