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                              October 8, 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
                                                            Response letter
dated September 30, 2020
                                                            File No. 001-11476

       Dear Mr. Carlson:

              We have reviewed your September 30, 2020 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
       September 11, 2020 letter.

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

       Management   s Discussion and Analysis of Financial Condition and
Results of Operations, page
       60

   1.                                                   We note that in
response to prior comments two, three and four, you have proposed to
                                                        remove or omit from
future periodic reports the line items for, and the discussions of,
                                                           gross profit    from
MD&A, your financial statements, and the operating segment note,
                                                        rather than present
complete measures of gross profit, reflecting all costs of revenues.

                                                        However, we note that
you have presented gross profit in your financial statements and
                                                        included discussion and
analysis of this metric as well as per barrel margins in your
                                                        periodic reports since
you began reporting more than eleven years ago.
 Chris Carlson
FirstName  LastNameChris Carlson
Vertex Energy  Inc.
Comapany
October    NameVertex Energy Inc.
        8, 2020
October
Page 2 8, 2020 Page 2
FirstName LastName

         We also note that you have retained various incomplete cost of
revenues measures and
         analysis of per barrel margins in your draft revisions, and have not
addressed the changes
         that would be necessary to discuss the excluded amounts in your
narratives on page 61, or
         to include complete measures along with the narratives presently
reflecting incomplete
         quantifications, including per barrel margin percentages.

         Please clarify the scope of revisions that you are contemplating and
explain to us how you
         came to view the measures that you are proposing to exclude as being
no longer important
         to users of your financial statements, and no longer useful in
describing the business, if
         this is your view, in formulating your proposed course of action.

         Please submit the incremental revisions necessary to balance your
discussion and analysis
         of cost of revenues and per barrel margins.

2.       We note that the revised tables provided in response to prior comment
two include the
         parenthetical    exclusive of items shown separately below    without
identifying the
         particular items and amounts excluded from cost of revenues.

         Please further revise your presentation to specify the items being
excluded from cost of
         revenues and if amounts shown on the line items excluded are not fully
attributable to the
         measure, quantify the attributable amounts in the parenthetical or
present separate lines for
         those amounts pertaining to cost of revenues. Based on the proposed
revisions to your
         segment tabulations, reporting    Operating depreciation and
amortization,    it appears that
         less than all of the DD&A reported is attributable to cost of
revenues.

         It also appears that the underscores between the line items cost of
revenues, and selling,
         general and administrative expenses, should be removed, in the absence
of any
         summations. Please revise accordingly.

3.       Please address the following points regarding the proposed revisions
provided in your
         response to prior comment two.

                In the second table, reporting segment loss before income
taxes, the line item
                 Depreciation and amortization from SG&A    should be revised
to clarify if the
              reference to    from SG&A    means    attributable to SG&A   .

                Please expand the statement "Our profit (loss) before corporate
selling, general and
              administrative expenses loss before income taxes is to a large
extent a function of the
              market discount we are able to obtain in purchasing feedstock, as
well as how
              efficiently management conducts operations" to clarify which
measure is being
              referenced and to quantify the discounts and efficiency
correlations.

                Your discussion of collection and production volumes should
also quantify the effects
 Chris Carlson
Vertex Energy Inc.
October 8, 2020
Page 3
              of changes in collections, relative to acquiring feedstock from
third-parties, on your
              cost of sales and measures of profitability.

Note 17 - Segment Reporting, page F-42

4.       In response to prior comment four, you agreed to report revenues for
each of the six
         product categories identified on pages 13 and 14 to comply with FASB
ASC 280-10-50-
         40, although your draft revisions did not include these details.

         Please submit details of all revisions being proposed, including
revenues based on the six
         product categories that you have identified, and revise your product
descriptions on pages
         13 and 14 to clarify which categories include or are synonymous with
vacuum gas oil and
         cutterstock, which you associate with the Black Oil segment in your
response.

        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
October 8, 2020 Page 3                                          Office of
Energy & Transportation
FirstName LastName