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Mail Stop 0510

October 5, 2004

via U.S. mail and facsimile

Mr. Daniel J. Heinrich
Senior Vice President - Chief Financial Officer
The Clorox Company
1221 Broadway
Oakland, California 94612

	RE:	The Clorox Company
		Form 10-K for the fiscal year ended June 30, 2004
		Filed August 27, 2004
		File No. 1-7151

Dear Mr. Heinrich:

	We have limited our review of the above referenced report to
environmental matter disclosures.  If you disagree with our comment,
we will consider your explanation as to why our comment is
inapplicable or a revision is unnecessary.  Please be as detailed as
necessary in your explanation.

	Please understand that the purpose of our review process is to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.  We
look forward to working with you in these respects.  We welcome any
questions you may have about our comment or on any other aspect of our
review.  Feel free to call us at the telephone numbers listed at the
end of this letter.

Note 20.  Guarantees and Contingencies - Environmental Matters, page
A-50

1. From the disclosures provided in Item 3 (Legal Proceedings)
regarding environmental matters, we note you have accrued $27.9
million for probable future costs which is recorded as a long-term
liability.  We remind you that SAB Topic 5:Y states that environmental
liabilities are of such significance that detailed disclosures
regarding the judgments and assumptions underlying the recognition and
measurement of the liabilities are necessary to inform readers fully
regarding the range of reasonably possible outcomes that could have a
material effect on your financial condition, results of operations, or
liquidity.  If there is a reasonable possibility that a loss exceeding
amounts already recognized may have been incurred and the amount of
that additional loss is material, please disclose the estimated
additional loss, or range of loss, or state that such an estimate
cannot be made as required by paragraph 10 of SFAS 5.  In addition,
provide the disclosures called for by SAB Topic 5:Y.  Provide us with
an example of the disclosure that you will include in future filings.

*    *    *    *

	Please respond to this comment within 10 business days, or tell
us when you will provide us with a response.  Please provide us with a
supplemental response letter that keys your response to our comment
and provides any requested supplemental information.  Detailed letters
greatly facilitate our review.  Please file your supplemental response
on EDGAR as a correspondence file.  Please understand that we may have
additional comments after reviewing your response to our comment.

We urge all persons who are responsible for the accuracy and adequacy
of the disclosure in the filings reviewed by the staff to be certain
that they have provided all information investors require.  Since the
company and its management are in possession of all facts relating to
a company`s disclosure, they are responsible for the accuracy and
adequacy of the disclosures they have made.

	In connection with responding to our comment, please provide, in
writing, a statement from the company acknowledging that:
* the company is responsible for the adequacy and accuracy of the
disclosure in their filings;
* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action with
respect to the filing; and
* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

	In addition, please be advised that the Division of Enforcement
has access to all information you provide to the staff of the Division
of Corporation Finance in our review of your filing or in response to
our comment on your filing.

If you have any questions regarding this comment, please direct them
to Nudrat Salik, Staff Accountant, at (202) 942-7769 or, in her
absence, to the undersigned at (202) 942-1774.

							Sincerely,



							Rufus Decker
							Accounting Branch Chief
Mr. Daniel J. Heinrich
October 5, 2004
Page 1 of 3




UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0404

       DIVISION OF
CORPORATION FINANCE




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