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                             July 26, 2022

       Pablo Brizzio
       Chief Financial Officer
       Ternium S.A.
       26 Boulevard Royal     4th floor
       L-2449 Luxembourg

                                                        Re: Ternium S.A.
                                                            Form 20-F for the 
Year Ended December 31, 2021
                                                            Form 6-K furnished 
April 27, 2022
                                                            Response Dated July 
19, 2022
                                                            File No. 1-32734

       Dear Mr. Brizzio:

              We have reviewed your July 19, 2022 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
       June 30, 2022 letter.

       Response Letter dated July 19, 2022

       Note 4. Segment Information, page F-40

   1.                                                   We note your response 
to our prior comment 7 but continue to have more questions on
                                                        your aggregation 
analysis of the four operating segments within the Steel reportable
                                                        segment. Please provide 
us the following information:

                                                              Aggregation 
analysis which includes the Other Regions operating segment
                                                              Financial 
information which includes both historical and projected results for each of
                                                            the four operating 
segments. This information should include revenue (internal and
                                                            external) as well 
as profit measures.
                                                              In light of your 
response that the Brazil segment produces slabs, most of which are
 Pablo Brizzio
Ternium S.A.
July 26, 2022
Page 2
              sold to your subsidiaries, please provide us a more detailed 
explanation as to why you
              believe the Brazil segment has similar nature of products and 
services, customers and
              production processes to the Mexico and Southern Region segments.

2.       We note your response to our comment number 8 and the proposed revised 
disclosure. It
         appears to us that you are still presenting an additional measure of 
segment profit or
         loss, titled "Management View." In light of the fact that your 
response indicates that you
         use operating income as your sole measure of segment profit or loss, 
please remove the
         disclosure of Management View sales and operating income to be 
consistent with the
         guidance in IFRS 8, paragraph 26.
      You may contact Charles Eastman at (202) 551-3794 or Claire Erlanger at 
(202) 551-
3301 with any questions.



FirstName LastNamePablo Brizzio                               Sincerely,
Comapany NameTernium S.A.
                                                              Division of 
Corporation Finance
July 26, 2022 Page 2                                          Office of 
Manufacturing
FirstName LastName