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                            October 28, 2021

       Raul Jacob
       Chief Financial Officer
       Southern Copper Corporation
       1440 East Missouri Avenue
       Suite 160
       Phoenix, AZ 85014

                                                        Re: Southern Copper
Corporation
                                                            Form 10-K for the
Fiscal Year Ended December 31, 2020
                                                            Response Dated
October 4, 2021
                                                            File No. 001-14066

       Dear Mr. Jacob:

              We have reviewed your October 4, 2021 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
       September 20, 2021 letter.

       Form 10-K for Fiscal Year Ended December 31, 2020

       General

   1.                                                   In your response to
comment 1, you state that you considered the indirect consequences of
                                                        climate-related
regulation or business trends and determined those consequences have not
                                                        been material. Please
tell us more about your basis for this determination by better
                                                        describing how how you
expect climate change to affect demand for your products or
                                                        impact your reputation.
Your response should specifically address the individual items
                                                        from our prior comment.
For example, your response notes an anticipated increase in
                                                        demand for certain
products you produce which are "essential in the manufacturing
                                                        processes of
technologies needed for migrating to low carbon economies," but does not
                                                        explain how it could
benefit you.
 Raul Jacob
Southern Copper Corporation
October 28, 2021
Page 2
2.       Your response to prior comment 2 states that you do not believe
weather-related impacts
         on your major customers or suppliers have been material. However, we
also note
         disclosure in your Form 10-K which states that the potential physical
impacts of climate
         change may adversely impact the cost, production, and financial
performance of your
         operations. Revise this disclosure to also address how weather-related
impacts may affect
         your customers or suppliers or further explain to us why you do not
believe they could
         potentially be affected.
3.       We note from your response to comment 3 that you do not believe
transition risks related
         to climate change are material to you or your operations. However, it
does not appear that
         you have addressed the specific elements of our prior comment or
explained the basis for
         your conclusion regarding materiality. Tell us about specific
transition risks, such as those
         related to policy and regulatory changes, market trends, credit risks,
or technological
         changes, and explain in more detail how you considered providing
expanded disclosure in
         your SEC filings.
4.       Your response to prior comment 4 states that there were no material
increased compliance
         costs related to regulations regarding climate change in the regions
where you operate.
         Tell us about the compliance costs you incurred to comply with laws
and regulations
         related to climate change and explain how you concluded the related
amounts were not
         material (with quantitative support).
5.       We note from your response to prior comment 5 that you had no material
purchase or sale
         of carbon credits or offsets for the periods presented. Provide us
with quantitative
         information to support this statement.
       You may contact Diane Fritz (Staff Accountant) at (202) 551-3331 or Brad
Skinner
(Office Chief) at (202) 551-3489 if you have questions.



FirstName LastNameRaul Jacob                                   Sincerely,
Comapany NameSouthern Copper Corporation
                                                               Division of
Corporation Finance
October 28, 2021 Page 2                                        Office of Energy
& Transportation
FirstName LastName