March 12, 2020

Jay Rembolt
Chief Financial Officer
WD 40 CO
9715 Businesspark Avenue
San Diego, CA. 92131

       Re: WD 40 CO
           Form 10-K for the year ended December 31, 2019
           Filed on October 22, 2019
           File No. 000-06936

Dear Mr. Rembolt:

       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 year ended August 31, 2019

Note 10. Revenue Recognition, page F-20

1.    You indicate that you estimate your transaction price using the most
likely method. Please
      tell us why it is appropriate to apply this method rather than the
expected value method
      given the characteristics of your contracts and the nature of your
promotional activities.
      See ASC 606-10-32-8.
        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 Ameen Hamady at 202-551-3891, or in his absence, Terence
O Brien at
202-551-3355 at if you have any questions.
 Jay Rembolt
WD 40 CO
March 12, 2020
Page 2


FirstName LastNameJay Rembolt   Sincerely,
Comapany NameWD 40 CO
                                Division of Corporation Finance
March 12, 2020 Page 2           Office of Life Sciences
FirstName LastName