VIA EDGAR

                                                        October 13, 2009

Mr. Karl Hiller
Branch Chief
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
Facsimile No.: (703) 813-6982


         Re: Chemical and Mining Company of Chile Inc.  Form 20-F for the
             Fiscal Year Ended December 31, 2008  Filed on June 30, 2009.
             Response Letter Dated September 17, 2009 File No. 033-65728

Dear Mr. Hiller:


         This letter is in response to the comment letter of the staff (the
"Staff") of the Securities and Exchange Commission (the "Commission") dated
September 30, 2009 (the "Comment Letter") related to the responses provided by
Chemical and Mining Company of Chile Inc. (the "Company") on September 17, 2009
in connection with its annual report on Form 20-F for the fiscal year ended
December 31, 2008 (the "Form 20-F")

         The Company's responses to the Staff's comments are set forth below.
References to the "Company", "we", "us" and "our" in the responses set forth
below are to the Company, unless the context otherwise requires. All references
in the Company's response to pages and captioned sections are to the Form 20-F
as originally filed. Capitalized terms used in this letter and not otherwise
defined herein have the meaning ascribed to them in the Form 20-F.

         For convenience, the Company has included the SEC staff's comments in
italics followed by the Company's response.




Form 20-F for the Fiscal Year ended December 31, 2008
- -----------------------------------------------------

Financial Statements
- --------------------

Note 2 - Summary of Significant Accounting Policies F-9
- -------------------------------------------------------

t) Revenue Recognition, Page F-19
- ---------------------------------

Comment 1:

1.       We note your response to prior comment 1, stating that you believe your
         revenue recognition policy under Chilean GAAP is consistent with U.S.
         GAAP. However, in our prior comment we also requested that you tell us
         about any transactions where revenue is recognized prior to the title
         being transferred. Please tell us under what conditions, if any, you
         would recognize revenue prior to the transfer of title, and explain why
         you believe under these conditions revenue is considered realizable and
         earned under both Chilean and U.S. GAAP.

Response 1:

Under no circumstances do we recognize revenues prior to the transfer of title
of goods to our customers.

Comment 2:

2.       We note your response to prior comment 2, explaining that there is no
         impact on the net income and stockholders' equity under U.S. GAAP as
         you defer recognizing the revenues related to goods invoiced but not
         delivered. However, we believe that the receivable recognized at the
         time the invoice is issued for goods not delivered represents a U.S.
         GAAP difference as well. In future filings, please address this
         difference in accounting in your U.S. GAAP reconciliation in the event
         the deferred revenue and related receivable amounts become material.

Response 2:

We agree that the receivable recognized at the time an invoice is issued for
goods not delivered represents a U.S. GAAP difference, as does the related
deferred revenue. However, to date, the amounts have not been material. We will
disclose the difference related to the recognition of deferred revenues and
corresponding receivables in future filings and we will include a corresponding
adjustment in our reconciliation to U.S GAAP at such time as the amounts
involved become material.



Comment 3:

3.       We note your response to prior comment 3, clarifying that the "income
         from sales by installment" relates to implied interest income from
         sales to your customers with extended payment terms and such
         transactions do not constitute installment sales. In future filings,
         please clarify your revenue recognition policy to specify the
         circumstances where implied interest income is recognized and refrain
         from describing such transactions as installment sales.

Response 3:

In future filings we will include a more accurate description of our revenue
recognition policy as it applies to transactions with extended payment terms
which involve implied interest income and we will not refer to those
transactions as "installment sales".

x) Provisions for Mine Closure Costs, page F-20
- -----------------------------------------------

Comment 4:

4.       We note your response to prior comment 4 in which you explain that your
         provision associated with the closure of your mining facilities is
         consistent with the U.S. GAAP guidance found is SFAS 143. Tell us
         whether Chilean GAAP requires you to capitalize an asset retirement
         cost upon initial recognition of a liability for an asset requirement
         obligation, which is consistent with the guidance in paragraph 11 of
         SFAS 143 for U.S. GAAP purposes. To the extent this corresponding asset
         is not recognized under Chilean GAAP, please address the impact this
         difference in accounting would have on your U.S. GAAP reconciliation.

Response 4:

Chilean GAAP does not address specifically treatment of the costs associated
with closure of mining facilities. However, Technical Bulletin 56 provides that
International Financial Reporting Standards should be followed in order to
determine the appropriate accounting treatment for certain transactions in the
absence of specific guidance under Chilean GAAP. Thus, under Chilean GAAP the
treatment of costs associated with the closure of mining sites is accounted for
in accordance with paragraph 16 of IAS 16, Property, Plant and Equipment
requiring capitalization of the initial estimate of the costs of dismantling and
removing the asset and restoring the site on which it is located with a
corresponding liability for the related obligation. This treatment is consistent
with the guidance in paragraph 11 of SFAS 143 for U.S. GAAP purposes.

However, as stated in our previous response to comment 4, we recognize new
obligations for closure of our mining facilities and changes in the estimated
amount of previously recognized obligations, directly as a charge to our income
statement as the obligation and respective asset retirement costs are not
material to our financial position, results of operations or cash flows. The
total asset retirement



obligation recognized in our consolidated balance sheets, which approximates the
unrecorded amount of property, plant and equipment represented 0.3% and 0.2% of
total Property, plant and equipment as of December 31, 2008 and 2007,
respectively. The effect of not recognizing the asset retirement cost in
accordance with SFAS 143 resulted in a decrease to our net income of less than
0.2% in any of the years ended December 31, 2008, 2007 and 2006.

In future filings we will more clearly disclose our accounting policy, and we
will include a corresponding adjustment to our primary financial statements (and
therefore in the reconciliation to U.S GAAP) at such time as the amounts
involved become material.

Should you have any question or comments about the responses in this letter,
please contact the undersigned at (56-2)-425-2485. Alternatively, please contact
Patricio Vargas at (56-2) 425-2274.



                                        Sincerely,

                                        /s/ Ricardo Ramos R.

                                        Ricardo Ramos R.
                                        Chief Financial Office & Business
                                        Development Senior Vice President



Date: October 13, 2009


VIA EDGAR AND TELECOPIER
- --- ----- --- ----------

cc:    Ms. Joanna Lam
       Ms. Jennifer Gallagher