Mail Stop 6010


						November 9, 2005



Via U.S. Mail and Facsimile (718-472-0794)

James J. Burke
Chief Financial Officer
Standard Motor Products, Inc.
37-18 Northern Blvd.
Long Island City, New York 11101


	Re:	Standard Motor Products, Inc.
		Form 10-K for year ended December 31, 2004
		Forms 10-Q for quarter ended March 31, 2004 and June 30,
2005
		File No. 001-04743

Dear Mr. Burke:

      We have reviewed your filings and response letter dated
August
30, 2005 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.  After reviewing this information, we
may
raise additional comments.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comment or on any other
aspects
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.







Form 10-K for the year ended December 31, 2005

Financial Statements, page 32

Reports of Independent Registered Public Accounting Firm, page 36

1. We note your response to our previous comment 1 in your
correspondence dated August 30, 2005.  We are continuing to
evaluate
your response to our comment.

Note 1. Summary of Significant Accounting Policies, page 43

Revenue Recognition, page 45

2. We note from your disclosure on page 12 that you "use
components
and cores (used parts)" in your remanufacturing processes for
"computerized electronics and air conditioning compressors" which
you
purchase "either from exchanges with customers who return cores
when
purchasing remanufactured parts, or through direct purchases from
a
network of core brokers."  Please address the following:
* Tell us and disclose in future filings how you account for these
transactions under either of the two situations.  That is, address
circumstances where you obtain the core from the customer and
those
circumstances where you obtain the core from a broker.
* Discuss the accounting and valuation for the related revenues,
cost
of revenues, and inventory.  Your response should address the
timing
of your journal entries and the accounting throughout the entire
process including obtaining the used part, placing the part into
inventory, remanufacturing that part and then selling the
remanufactured part to a customer.
* Cite the accounting literature upon which you relied and how you
applied that literature to your situation.
* Include a description of the significant terms of your
arrangements
with customers whereby you obtain cores through exchanges with
them.
* Quantify, to the extent practicable, the impact of these
purchases
and sales on your total revenues, cost of revenues and inventory.



Item 9A. Controls and Procedures, page 75

3. We note the disclosure that your principal executive officer
and
principal financial officer have evaluated your disclosure
controls
and procedures as of a date within 90 days before the filing date
of
your annual report.  Please confirm that the evaluation was
performed
as of the end of the period covered by the report as required by
Item
307 and revise future filings to indicate that fact.  Refer to
Item
307 of Regulation S-K and Part III.F of Management`s Reports on
Internal Control Over Financial Reporting and Certification of
Disclosure in Exchange Act Periodic Reports, Release No. 33-8238,
available on our website at www.sec.gov/rules/final/33-8238.htm.

Forms 10-Q for the quarters ended March 31, 2005 and June 30, 2005

Item 4.  Controls and Procedures

4. We see that you do not state your conclusion as to whether your
disclosure controls and procedures were effective as of the end of
the period covered by the reports.  Instead you state the
conclusions
reached as of December 31, 2004 but not as of the two quarters
ended
March 31, 2005 and June 30, 2005.  Please amend your Forms 10-Q to
clearly disclose the conclusion reached by your Chief Operating
Officer and Chief Financial Officer regarding the effectiveness of
disclosure controls and procedures as of the end of each period
covered by your reports.

5. We note your statement that "any controls and procedures, no
matter how well designed and operated, can provide only reasonable
assurance of achieving the desired control objectives."  Please
revise to also state clearly, if true, that your disclosure
controls
and procedures are designed to provide reasonable assurance of
achieving their objectives and that your principal executive
officer
and principal financial officer concluded that your disclosure
controls and procedures are effective at that reasonable assurance
level.  In the alternative, remove the reference to the level of
assurance of your disclosure controls and procedures.  Please
refer
to Section II.F.4 of Management`s Reports on Internal Control Over
Financial Reporting and Certification of Disclosure in Exchange
Act
Periodic Reports, SEC Release No. 33-8238, available on our
website
at .




      As appropriate, please amend your filings and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  Please furnish a cover letter with your
amendment
that keys your responses to our comments and provides any
requested
information.  Detailed cover letters greatly facilitate our
review.
Please file your cover letter on EDGAR.  Please understand that we
may have additional comments after reviewing your amendment and
responses to our comments.

      You may contact Praveen Kartholy, Staff Accountant, at (202)
551-3778 or me at (202) 551-3671 if you have questions regarding
these comments.


							     Sincerely,



							    Martin F. James
							    Senior Assistant Chief
Accountant

Mr. James J. Burke
Standard Motor Products, Inc.
November 9, 2005
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