July 25, 2018

Daniel O'Brien
President
Flexible Solutions International, Inc.
6001 54 Ave.
Taber, Alberta Canada T1G 1X4

       Re: Flexible Solutions International, Inc.
           Amendment No. 1 to Form S-4
           Filed July 11, 2018
           File No. 333-225185

Dear Mr. O'Brien:

       We have limited our review of your registration statement to those
issues we have
addressed in our 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 this letter by amending your registration statement
and providing the
requested information. If you do not believe our comments apply to your facts
and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

       After reviewing any amendment to your registration statement and the
information you
provide in response to these comments, we may have additional comments.

Amendment No. 1 to Form S-4 filed July 11, 2018

General, page 1

1.     We note your response to comment one in our letter dated June 20, 2018.
We note that
       you have omitted information required by Part A of Form S-4. Please
provide the
       information required by Item 3 including providing a summary in the
forepart of the
       prospectus of Form S-4.
Incorporation of Documents by Reference5, page 5

2.     We note your response to comment two of our letter dated June 20, 2018.
General
       Instruction B of Form S-4 provides that such incorporation by reference
is permissible if
 Daniel O'Brien
Flexible Solutions International, Inc.
July 25, 2018
Page 2
         one of the conditions set forth in General Instruction B.1.a(ii) is
met. Given that the
         aggregate market value of your common equity held by non-affiliates
appears to be below
         the minimum public float requirements of General Instruction I.B.1 of
Form S-3, you may
         not be eligible to incorporate information about the registrant by
reference at this time.
         Either provide us with an analysis demonstrating compliance with the
applicable
         provisions of General Instruction B of Form S-4, or otherwise, please
amend your
         registration statement to include the required information.
        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

        Please contact Sherry Haywood, Staff Attorney at (202) 551-3345 or Asia
Timmons-
Pierce, Special Counsel at (202) 551-3754 with any questions.


FirstName LastNameDaniel O'Brien
                                                              Division of
Corporation Finance
Comapany NameFlexible Solutions International, Inc.
                                                              Office of
Manufacturing and
July 25, 2018 Page 2                                          Construction
FirstName LastName