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                                HART & HART, LLC
                                ATTORNEYS AT LAW
                             1624 Washington Street
                                Denver, CO 80203
William T. Hart, P.C.              ________                   harttrinen@aol.com
Will Hart                       (303) 839-0061               Fax: (303) 839-5414


                                  July 10, 2018

Sherry Haywood
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549

      Re:   Flexible Solutions International, Inc.
            Form S-4
            File No. 333-225185


     This office represents Flexible Solutions International, Inc. Amendment No.
1 to the  Company's  Registration  Statement on Form S-4 has been filed with the
Commission.  This letter is response to the staff's  letter dated June 20, 2018.
The paragraph numbers in this letter correspond with the numbered  paragraphs in
the staff's letter.

     1. The information required by Part A has either been:

          o    added to the prospectus by means of Amendment No. 1 (see pages 3,
               4 and 37);

          o    was in the  originally  filed  Registration  Statement  (i.e. the
               Company's name, mailing address and telephone number, description
               of Company's business, incorporation of documents by reference);

          o    is not applicable  since the  Registration  Statement  involves a
               change in the Company's corporate domicile and not an acquisition
               (i.e. Items 4, 5, 6 and 7); or

          o    is not applicable in general (Item 8).

     2. The staff is of the opinion that the Company is not able to  incorporate
the information required by Item 12 by reference since the Company does not meet
the  aggregate  market  value  requirement  of  instruction  1.B.1 of Form  S-3.
However,  the aggregate market value requirement only applies to Items 10 and 11
of Form S-4.

     Instruction  B.1.(b) to Form S-4 allows a registrant to provide information
in  accordance  with  Items 12 and 13 of the form if the  registrant  meets  the
requirements for the use of Form S-3.  Instruction B.1.(b) makes no reference to
any aggregate market value requirement.

                                       1
<PAGE>

     In the  proposing  release  with  respect  to the use of Form S-4  (Release
33-6534,  page 13), it was proposed that general  instruction B.1. would read as
follows:

     a)   Information  with  respect  to the  registrant  shall be  provided  in
          accordance  with  the  items   referenced  in  one  of  the  following
          subparagraphs:

          (i)  Items 10 and 11 of this Form,  if the  registrant  would meet the
               requirements  for use of Form S-3  (ss.239.13 of this chapter) if
               it were making a primary  offering of securities  and elects this
               alternative;

          (ii) Items 12 and 13 of this Form,  if the  registrant  would meet the
               requirements  for use of Form S-2  (ss.239.12 of this chapter) or
               Form S-3 if it were making a primary  offering of securities  and
               elects this alternative; or

          (iii) Item 14 of this  Form,  if the  registrant  would  not  meet the
               requirements  for use of  Form  S-2 or S-3 if it  were  making  a
               primary  offering of securities,  or if it otherwise  elects this
               alternative.

     However,   in  the  adopting  release  (Release  33-6578,   page  38),  the
requirement  that a  registrant,  in order to use  Items 12 and 13 of Form  S-4,
would need to meet the requirements for the use of Form S-3 "if it were making a
primary  offering of its  securities"  was deleted and replaced simply by "meets
the requirements" for use of Form S-3.

     The adopting release (page 8) also provided the following:

          "General Instruction B explains the operation of the three-tier system
          in the context of registration  on Form S-4 and, as adopted,  reflects
          certain clarifying language changes."

     Note the use of the words "three-tier system". In the proposing release, it
was actually a two-tier system since Instruction B.1.a and B.1.b. were, with the
exception  of the  reference  to  Form  S-2,  the  same.  The  reference  to the
three-tier system clearly means that the requirements for the use of:

     o    Items 10 and 11; and

     o    Items 12 and 13,

are not the same.

     The Company  meets the  requirements  for the use of Form S-3 and should be
able to incorporate the information required by Item 12 by reference.

                                       2
<PAGE>

     Insofar as Item 10 is concerned,  the information  required by this item is
not applicable since:

     o    there have been no material changes to the Company's business;

     o    the Company has not entered into any  transaction  which would require
          the  presentation  of  financial  statements  required by Rule 3-05 or
          Article 11 of Regulation S-K;

     o    the Company has not restated its financial statements; and

     o    there has been no material disposition of the Company's assets.

     If you should have any questions  concerning the  foregoing,  please do not
hesitate to contact the undersigned.

                                          Very Truly Yours,

                                          HART & HART, LLC

                                          /s/ William T. Hart
                                       By
                                          William Hart
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