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                              October 18, 2022

       Pablo Brizzio
       Chief Financial Officer
       Ternium S.A.
       26 Boulevard Royal     4th floor
       L-2449 Luxembourg

                                                        Re: Ternium S.A.
                                                            Form 20-F for the
Year Ended December 31, 2021
                                                            Form 6-K furnished
April 27, 2022
                                                            Response Dated
August 11, 2022
                                                            Response Dated July
19, 2022
                                                            File No. 1-32734

       Dear Pablo Brizzio:

              We have reviewed your August 11, 2022, 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. Unless we note otherwise, our references to prior comments are
to comments in our
       August 11, 2022, letter.

       Response Letter Dated August 11, 2022

       Note 4. Segment Information, page F-40

   1.                                                   In the September 27,
2022 conference call with the Staff, you stated that you currently
                                                        manage and operate your
business as two operating and reportable segments: Mining and
                                                        Steel. Please reconcile
the differences in this segment structure to the structure disclosed
                                                        on page F-40 in your
Form 20-F for the year ended December 31, 2021 and also described
                                                        in your comment letter
responses dated July 19, 2022 and August 11, 2022. Specifically,
                                                        address the change from
the previously disclosed aggregation of the Mexico, Southern
                                                        Region, Brazil, and
Other Markets operating segments into the Steel reportable segment.
                                                        Also, clarify for us
whether you have aggregated operating segments within the two
 Pablo Brizzio
Ternium S.A.
October 18, 2022
Page 2
         operating and reporting segments.
2.       Please provide us with your operating segment identification analysis
performed in
         accordance with paragraphs 5 to 10 of IFRS 8. As part of your
response, please provide us
         with the following:

                Provide us with details about your management structure and how
your company is
              organized;
                Describe the role of your CODM and each of the individuals
reporting to the CODM;
                Identify and describe the role of each of your segment
managers;
                Describe the key operating decisions, who makes these
decisions, how performance
              is assessed and how resources are allocated within your business;
                Tell us how often the CODM meets with his direct reports, the
financial information
              the CODM reviews in conjunction with those meetings, and the
other participants at
              those meetings;
                Explain how budgets are prepared, who approves the budget at
each step of the
              process, the level of detail discussed at each step, and the
level at which the CODM
              makes changes to the budget; and
                Describe the basis for determining the compensation for each
individual that reports
              to the CODM.
3.       Describe the financial information reviewed by the CODM for the
purpose of allocating
         resources and assessing performance. Tell us how frequently that
information is prepared
         and reviewed. Also describe the financial information reviewed by your
Board of
         Directors and how frequently that information is reviewed. In this
regard, we note that you
         present disaggregated revenue information for Mexico, Southern Region,
and Brazil and
         Other Markets on pages 46, 77, and 81 of your Form 20-F. Tell us
whether the CODM or
         the Board of Directors receives any profitability and/or expense
information for these
         regions separately. If so, describe the nature, type and frequency of
that information.
      You may contact Charles Eastman at (202) 551-3794 or Claire Erlanger at
(202) 551-
3301 with any questions.



FirstName LastNamePablo Brizzio                               Sincerely,
Comapany NameTernium S.A.
                                                              Division of
Corporation Finance
October 18, 2022 Page 2                                       Office of
Manufacturing
FirstName LastName