June 12, 2019

John P. Zimmer
Chief Financial Officer
CORE MOLDING TECHNOLOGIES INC
800 Manor Park Drive
Columbus, Ohio 43228

       Re: CORE MOLDING TECHNOLOGIES INC
           Form 10-K for the Year Ended December 31, 2018
           Filed March 18, 2019
           Form 10-Q for the Quarter Ended March 31, 2019
           Filed May 9, 2019
           File No. 001-12505

Dear Mr. Zimmer:

       We have limited our review of your filing to the financial statements
and related
disclosures 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-Q for the Quarter Ended March 31, 2019

Item 4. Controls and Procedures, page 28

1.    Please revise to disclose any change in your internal control over
financial reporting that
      occurred during the last fiscal quarter that has materially affected, or
reasonably likely to
      materially affect, your internal control over financial reporting. Refer
to Item 308 (c) of
      Regulation S-K.
 John P. Zimmer
FirstName LastNameJohn P. Zimmer INC
CORE MOLDING TECHNOLOGIES
Comapany NameCORE MOLDING TECHNOLOGIES INC
June 12, 2019
June 12, 2019 Page 2
Page 2
FirstName LastName
Form 10-K for the Year Ended December 31, 2018

Management's Discussion and Analysis of Financial Condition and Results of
Operations
Liquidity and Capital Resources
Bank Covenants, page 28

2.       We note that as of December 31, 2018, you were in violation of the
financial covenants
         associated with the loans made under the A/R Credit Agreement and that
you
         subsequently entered into an amendment which waived the non-compliance
as of
         December 31, 2018 and established new covenant levels. Please revise
to disclose the
         specific terms of any significant financial covenants that you are
subject to, including the
         required and actual ratios/amounts as of each reporting date.
Notes to Financial Statements
1. Basis of Presentation, page 40

3.       Please expand your disclosure to clarify if your two reporting units,
Core Traditional and
         Horizon Plastics, are two individual operating segments that are being
aggregated into one
         reportable operating segment based on the guidance in ASC
280-10-50-11, or if you only
         have one operating segment based on the guidance in ASC 280-10-50-1.
If you have
         multiple operating segments that are being aggregated into one
reportable segment, please
         also expand your disclosures to clarify that all of the requirements
in ASC 280-10-50-11
         have been met and provide the information required by ASC
280-10-50-21. If you believe
         that you only have one operating segment, please provide us with and
disclose your
         analysis under ASC 280-10-50-1, including a discussion of the
frequency and contents of
         the discreet information for the two reporting units that is regularly
reviewed by your
         CODM to allocate resources and assess performance.
2. Summary of Significant Accounting Policies
Goodwill, page 41

4.       We note that you fully impaired the goodwill associated with Core
Traditional as a result
         of the annual impairment assessment performed on December 31, 2018.
Please expand
         your disclosure to discuss the events and circumstances that resulted
in the impairment.
         Also tell us if you performed any interim impairment tests during 2018
and explain why
         or why not. In this regard, we note that your stock price continued to
decline significantly
         throughout 2018 from a high of $21.65 in January to a low of $6.40 in
October. In
         addition, tell us what, if any, cautionary disclosures regarding the
potential for a
         significant goodwill impairment charge you provided in filings prior
to your 2018 Form
         10-K. To the extent prior disclosures were not provided, please
explain why.
5.       You state that based on your December 31, 2018 annual impairment
assessment, the
         goodwill assigned to the Horizon Plastics reporting unit was not
impaired as the fair value
         was 23% above the carrying value. Please provide us with a
reconciliation of the fair
 John P. Zimmer
CORE MOLDING TECHNOLOGIES INC
June 12, 2019
Page 3
         value of your reporting units to your total market capitalization as
of December 31, 2018.
Long-Lived Assets, page 41

6.       Definite-lived intangible assets appear significant to your balance
sheet at $15.4 million as
         of December 31, 2018, 55% of which representing customer
relationships. Considering
         recent full impairment of goodwill assigned to Core Traditional,
continued significant
         decline in your operating results and stock price, and your statement
on page 17 regarding
         your inability to consistently meet customer delivery and quality
requirements due to asset
         capacity and labor constraints, please tell us and disclose if and how
you assessed the
         recoverability of your intangible assets including customer
relationships under ASC 360-
         10-35, and the results of your impairment testing, methodology,
significant estimates and
         underlying assumptions.
       In closing, 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 SiSi Cheng at 202-551-5004 or John Cash at 202-551-3768
with any
questions.



                                                               Sincerely,
FirstName LastNameJohn P. Zimmer
                                          Division of Corporation Finance
Comapany NameCORE MOLDING TECHNOLOGIES INC
                                          Office of Manufacturing and
June 12, 2019 Page 3                      Construction
FirstName LastName