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                                                             December 12, 2019

Ian Cameron
Chief Financial Officer
METHANEX CORP
1800 Waterfront Centre
200 Burrard Street
Vancouver, British Columbia
Canada V6C 3M1

       Re: METHANEX CORP
           Form 40-F for Fiscal Year Ended December 31, 2018
           Filed March 12, 2019
           File No. 000-20115
           Response Dated December 3, 2019

Dear Mr. Cameron:

       We have reviewed your December 3, 2019 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.

Form 40-F for Fiscal Year Ended December 31, 2018

2. Significant accounting policies
n) Revenue recognition, page 56

1.     We note your response to comment 1 in our letter dated November 6, 2019.
Specifically,
       you note that only sales of product from your Atlas joint venture
facility are recognized on
       a commission basis. However, we note your disclosure on page 11 of
Exhibit 99.2 of
       Form 40-F that volume produced at your Egypt facility is also recognized
on a
       commission basis. Please advise.
2.     We note the accounting analysis you have provided in concluding you are
the agent in the
       contracts with your customers that are fulfilled with methanol produced
by the Atlas joint
 Ian Cameron
METHANEX CORP
December 12, 2019
Page 2
         venture facility. Specifically, you state you do have legal ownership
of the commission
         volume prior to selling to your customers. Please tell us if this
legal ownership is only
         momentarily before transfer. Refer to IFRS 15.B35. If the legal
ownership is not a flash
         title, please tell us why you believe you need to consider the
indicators of control
         discussed in IFRS 15.B37. Refer to IFRS 15.B37A for additional
guidance. To the extent
         that the indicators are necessary for determining control, please tell
us how you
         determined that you do not have inventory risk solely because you
obtain insurance that
         you are reimbursed. Refer to IFRS 15.B37(b) for guidance. Also, please
tell us who is
         primarily responsible for fulfilling the promise to provide methanol
to your customer.
         Refer to IFRS 15.B37(a). Finally, please tell us whether you are a
principal or agent in
         your sales of methanol purchased from other third party suppliers and
how your
         evaluation of significant indicators of control differs.
o) Financial instruments, page 56

3.       We note your response to comment 2 in our letter dated November 6,
2019. Based on your
         disclosures and response, the variability in pricing in the supply
contract is based on the
         price of methanol rather than revenue, which is derived from the
pricing of methanol and
         the quantities sold to your customers. Please provide us with a more
comprehensive
         explanation for your conclusion that methanol price is a non-financial
variable. Provide
         the specific details of the calculation of the variable price
component. Explain how you
         determined the price of a commodity could be a non-financial variable
akin to revenue
         when it does not factor in the quantity sold. Explain your basis for
considering a strong
         correlation between quantities of natural gas used and methanol
produced and sold as a
         factor in the analysis.
      You may contact Tracey Houser, Staff Accountant, at (202) 551-3736, or
Terence
O'Brien, Accounting Branch Chief, at (202) 551-3355, if you have questions
regarding
comments on the financial statements and related matters.



FirstName LastNameIan Cameron                                 Sincerely,
Comapany NameMETHANEX CORP
                                                              Division of
Corporation Finance
December 12, 2019 Page 2                                      Office of Life
Sciences
FirstName LastName
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