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                              September 11, 2020

       Chris Carlson
       Chief Financial Officer
       Vertex Energy Inc.
       1331 Gemini Street, Suite 250
       Houston, TX 77058

                                                        Re: Vertex Energy Inc.
                                                            Form 10-K for the
Fiscal Year ended December 31, 2019
                                                            Filed March 4, 2020
                                                            File No. 001-11476

       Dear Mr. Carlson:

              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 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.

       Form 10-K for the Fiscal Year ended December 31, 2019

       General

   1.                                                   The comments in this
letter refer to certain financial presentations and disclosures in your
                                                        annual report. However,
our concerns extend to the corresponding financial
                                                        presentations and
disclosures in your subsequent interim reports.

                                                        Please submit the
revisions that you propose in response to each comment for the annual
                                                        report and for the
subsequent interim reports.
       Management's Discussion and Analysis of Financial Condition and Results
of Operations
       Results of Operations, page 60

   2.                                                   We note that you
present fourth quarter results of operations along with segment details
                                                        on pages 62 and 63,
using incomplete cost of revenues and gross profit measures, and
                                                        listed depreciation and
amortization as an operating expense along with selling, general
 Chris Carlson
FirstName  LastNameChris   Carlson
Vertex Energy  Inc.
Comapany 11,
September  NameVertex
               2020    Energy Inc.
September
Page 2     11, 2020 Page 2
FirstName LastName
         and administrative expense.

         We also see various references to these metrics in the accompanying
narratives and note
         that you have taken a similar approach with the tabulations and
narratives pertaining to the
         annual results on pages 65 through 68, and with the quarterly details
on pages 69 and 70.

         Please revise as necessary to identify your non-GAAP measures with
distinct labeling, to
         provide balanced disclosures in the narratives with the most directly
comparable measures
         calculated in accordance with GAAP, and to provide the reconciliations
required by Item
         10(e) of Regulation S-K.

         Please also modify disclosures about changes in collection and
production volumes to
         clarify the effects on revenues and inventories.
Consolidated Statements of Operations, page F-6

3.       We note that you present incomplete cost of revenues and gross profit
measures,
         excluding depreciation and amortization that is attributable to cost
of revenues. Although
         the guidance in SAB Topic 11:B provides an accommodation for
presenting depreciation
         and amortization that is attributable to cost of revenues separately
from other amounts
         comprising the cost of revenues, this does not extend to measures of
gross profit.

         Please revise your presentation as necessary to show the portion of
depreciation and
         amortization that is attributable to cost of revenues within your
measure of gross profit.
         For example, this may be shown on a separate line directly below cost
of revenues
         excluding depreciation and amortization, and above the measure of
gross profit.
Financial Statements
Note 17 - Segment Reporting, page F-42

4.       We note that you identify six product categories from which you derive
substantially all
         revenues on pages 13 and 14, and indicate some correlation of these
products with your
         operating segments on pages 60 and 61, although the extent of
distinction is unclear. We
         also note that changes in your operating results are both generally
and specifically
         attributed to changes in the production or sale of these products in
MD&A.

         Please expand your disclosure on page F-42 to clarify the extent to
which each of your
         operating segments reflect sales of these various product categories
and to report revenues
         for each product category to comply with FASB ASC 280-10-50-40.


        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.
 Chris Carlson
Vertex Energy Inc.
September 11, 2020
Page 3

        You may contact Mark Wojciechowski, Staff Accountant at (202) 551-3759
or Karl
Hiller, Branch Chief, at (202) 551-3686 if you have questions regarding
comments on the
financial statements and related matters.



FirstName LastNameChris Carlson                          Sincerely,
Comapany NameVertex Energy Inc.
                                                         Division of
Corporation Finance
September 11, 2020 Page 3                                Office of Energy &
Transportation
FirstName LastName