Acme United Corporation
60 Round Hill Road
Fairfield, CT 06824


June 17, 2009

Terence O'Brien, Accounting Branch Chief
Securities and Exchange Commission
Washington, D.C. 20549-0404
RE: Acme United Corporation


Dear Mr. O'Brien:


This letter is in response to your letter dated June 4, 2009. Each of your
comments accompanied by our response is provided below.


     1.   Your response to comment 4 indicates that you do not disclose the
          provision for customer rebates for competitive reasons. We note that
          there was a 10% decrease in your liability for vendor rebates during
          2008 that represents 6% of 2008 net income. Please revise future
          filings to disclose in detail the reasons for any significant changes
          in your liability balance as well as to discuss the impact this
          activity has had on operations and cash flows. Given the significant
          change in the liability balance during 2008, this information would
          enhance a reader's understanding of you incentive program and its
          overall impact to your financial statements without jeopardizing your
          business competitively.


          Response
          --------

          We note your comment and will revise our disclosure in future filings
          to discuss the reasons for any significant changes in your liability
          balance as well as to discuss the impact this activity has had on
          operations and cash flows.


     2.   We note that your chief executive officer and chief financial officer
          concluded your disclosure controls and procedure "...were effective
          and sufficient to ensure that we record, process, summarize and report
          information required to be disclosed by us in our periodic reports
          filed under the Securities and Exchange Commission's rules and forms."
          This is an incomplete definition of disclosure controls and procedure
          per Rules 13a-15(e) and 15d-15(c) of the Exchange Act. Please confirm
          to us and revise your disclosure in future filings to clarify, if
          true, that your officer concluded that your disclosure controls and
          procedures are effective to ensure that information required to be
          disclosed by you in the reports that you file or submit under the
          Exchange Act is recorded, processed, summarized and reported, within
          the time periods specified in the Commission's rules and forms and to
          ensure that information required to be disclosed by an issuer in the
          reports that it files or submits under the Exchange Act is accumulated
          and communicated to your management, including its principal executive
          and principal financial officers, or persons performing similar
          functions, as appropriate to allow timely decisions regarding required
          disclosure. Otherwise in future filings, please simply conclude that
          you disclosure controls and procedures are effective or ineffective,
          whichever the case may be.


          Response
          --------

          We note your comment and will revise our disclosure in future filings
          to state that our disclosure controls and procedures are effective or
          ineffective, whichever the case may be.