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                            May 20, 2020

       Benjamin Schlater
       Chief Financial Officer
       FERRO CORPORATION
       6060 Parkland Boulevard
       Suite 250
       Mayfield Heights, Ohio 44124

                                                        Re: FERRO CORPORATION
                                                            Form 10-K for the
Year Ended December 31, 2019
                                                            Form 8-K
                                                            Filed March 2, 2020
                                                            File No. 1-00584

       Dear Mr. Schlater :

              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-K for the Year Ended December 31, 2019

       Note 21. Reporting for Segments, page 92

   1.                                                   We note that your
business is divided into four business units based on disclosures
                                                        provided on page 3:
Tile Coating Systems, Porcelain Enamel, Performance Colors and
                                                        Glass, and Color
Solutions. During the year ended December 31, 2018, the Tile Coating
                                                        Systems and Porcelain
Enamel business units were combined into one reportable segment
                                                        called Performance
Coatings. The Tile Coating Systems business unit is now reported as
                                                        discontinued operations
and the remaining Porcelain Enamel business unit has
                                                        been integrated into
the Performance Colors and Glass reportable segment. The
                                                        Performance Coatings
reportable segment reported $734 million in revenues for the year
                                                        ended December 31, 2018
of which $530 million was reported in discontinued operations
                                                        related to the Tile
Coatings business. This indicates that approximately $204 million of
 Benjamin Schlater
FERRO CORPORATION
May 20, 2020
Page 2
         revenues during the year ended December 31, 2018 were related to the
Porcelain Enamel
         business unit compared to 2018 consolidated revenues of $1.08 million
reported in the
         Form 10-K for the year December 31, 2019. Please tell us how you
determined it was
         appropriate to integrate the Porcelain Enamel business unit into the
Performance Colors
         and Glass reportable segment under ASC 280, including your
consideration of the
         aggregation criteria of ASC 280-10-50-11.
Form 8-K Filed March 2, 2020

Table 6, page 12

2.       We note your adjustment for costs related to optimization projects of
$13.6 million
         represents approximately 40% of your as reported net income
attributable to common
         shareholders and approximately 20% of your as adjusted net income
attributable to
         common shareholders. Please provide us with further details regarding
the components of
         these adjustments for each period presented and help us understand why
these costs would
         not be considered to be normal, recurring cash operating expenses.
Refer to Question
         100.01 of the Non-GAAP Financial Measures Compliance and Disclosure
Interpretations.
         In a similar manner, please address the appropriateness of adjusting
for these amounts in
         your determination of Adjusted Free Cash From Operating Activities.
Table 12, page 19

3.       In your determination of Free Cash Flow Provided by Operating
Activities, you adjust for
         cash collected for Accounts Receivable Securitizations. Given that ASC
230-10-45-12
         requires these amounts to be presented in investing activities, please
tell us how you
         determined that this adjustment does not result in a non-GAAP measure
based on
         individually tailored accounting principles. Refer to the guidance in
Question 100.04 of
         the Compliance and Disclosure Interpretations on Non-GAAP Financial
Measures.
       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 Nudrat Salik at (202) 551-3692 or Daniel Gordon at (202)
551-3486
with any questions.



FirstName LastNameBenjamin Schlater                          Sincerely,
Comapany NameFERRO CORPORATION
                                                             Division of
Corporation Finance
May 20, 2020 Page 2                                          Office of Life
Sciences
FirstName LastName