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                             September 22, 2022

       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, 2021
                                                            Filed March 14,
2022
                                                            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, 2021

       Business, page 7

   1.                                                   We note that you have
provided many details under this heading although have not
                                                        included individual
page numbers within the Business section such that the entire section
                                                        is associated with a
single page, and that both the Business and Risk Factor sections are
                                                        associated with a
single page in your Table of Contents

                                                        Please utilize page
numbers where generally appropriate or conducive to navigation
                                                        through and
comprehension of the disclosures that you provide.
       Management's Discussion and Analysis of Financial Condition and Results
of Operations
       Results of Operations, page 60

   2.                                                   We note that your
discussion and analysis does not appear to extend to any particular
                                                        aspects of the UMO
Business that you are reporting as discontinued operations, other than
 Chris Carlson
FirstName  LastNameChris   Carlson
Vertex Energy  Inc.
Comapany 22,
September  NameVertex
               2022    Energy Inc.
September
Page 2     22, 2022 Page 2
FirstName LastName
         your reference to the associated net income on page 60. Given the
termination of your sale
         agreement in January 2022, it would appear that further discussion and
analysis of its
         operations should be provided in advance of securing an alternative
sale.

         Please also expand the discussion and analysis in your subsequent
interim reports to
         include quantification of volumes managed or processed by your
operating segments,
         effects attributed to your recently acquired refinery operations, and
differentiation
         between changes in revenues attributable to volumes and prices.
Financial Statements
Note 12 - Earnings Per Share, page F-43

3.       Please address the requirement to provide a reconciliation of the
numerators and the
         denominators of the basic and diluted per share computations for
income from continuing
         operations as prescribed by FASB ASC 260-10-50-1.
Note 17 - Segment Reporting, page F-49

4.       We note that you have maintained your description of products sold by
the Black Oil
         operating segment, as reported in prior years, with no apparent change
to reflect your
         planned sale of the UMO Business, which you have reclassified as
discontinued
         operations. However, you previously reported significant sales for the
Black Oil segment
         including base oil, industrial fuel, other re-refinery products, and
VGO/marine fuel sales,
         all of which are now shown in your report to be zero.

         Please revise your disclosures as necessary to address the change in
segment composition
         and to provide the information prescribed by FASB ASC 280-10-50-21,
including the
         specific factors used to identify your reportable segments, the basis
of organization, and
         an indication of whether operating segments have been aggregated.
Note 19 - Discontinued Operations, page F-52

5.       We note that you began reporting the UMO Business as discontinued
operations when
         filing your interim report for the quarter ended September 30, 2021,
and that although the
         agreement was terminated on January 25, 2022 without a sale, you
continue to report the
         UMO Business as discontinued operations.

         Under FASB ASC 205-20-45-1F, you would ordinarily need to reclassify
the UMO
         Business as held and used if you no longer meet the criteria in 45-1E,
although it appears
         you would consider whether an exception to the time period would be
available under 45-
         1G(c), while otherwise meeting the criteria in 45-1E.

         Tell us how you have considered this criteria subsequent to the
termination. For example,
         given that you had sought shareholder approval for the original plan
of sale, please clarify
         whether you would not also need to obtain shareholder approval for a
new plan of sale
         prior to meeting the criteria in FASB ASC 205-20-45-1E(a).
 Chris Carlson
Vertex Energy Inc.
September 22, 2022
Page 3

         Please describe your efforts to sell the UMO Business subsequent to
the termination, with
         details sufficient to understand how you would fairly characterize the
UMO Business as
         "being actively marketed at a price that is reasonable given the
change in circumstances,"
         with reference to the previously contemplated terms of sale,
clarifying how your
         asking price compares to previous arrangement and fair value of the
UMO Business.

         Please provide any additional details that are necessary to show how
you have
         appropriately concluded that sale within one year is probable and that
actions required to
         complete the plan indicate that it is unlikely that significant
changes to the plan will be
         made or that the plan will be withdrawn, if this is your view.
6.       We note that you have numerous disclosures throughout your filing
equating the
         discontinued operations with your Black Oil Segment and the UMO
Business. However,
         while you report the UMO Business as discontinued operations, you also
report activity
         for the Black Oil segment in Note 17.

         Please revise disclosures regarding the discontinued operations and
operating segments
         throughout the filing as necessary to differentiate between the UMO
Business and the
         operations of the Black Oil segment to be retained and which you
continue to report.
        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 Joseph Klinko, Staff Accountant, at (202) 551-3824 or
Karl
Hiller, Branch Chief, at (202) 551-3686 with any questions.



FirstName LastNameChris Carlson                                Sincerely,
Comapany NameVertex Energy Inc.
                                                               Division of
Corporation Finance
September 22, 2022 Page 3                                      Office of Energy
& Transportation
FirstName LastName