The Mosaic Company (MOS) CORRESPCorrespondence with SEC

As requested by the Staff on June 16, 2020, during a telephone conversation with John Coleman, George Schuler, and Craig Arakawa, the following is a brief summary of why Mosaic does not report cutoff grades and mineral price assumptions.

Mosaic’s Potash segment is vertically integrated and the mined product is used to manufacture potash fertilizer. The potash beds in Saskatchewan are very extensive, covering dozens of kilometers. Our exploration techniques for calculating reserves and resources include vertical drill holes and tightly spaced “3D” seismic surveys. Areas within 1 mile radius of the drill holes are considered reserve, and the 3D seismic surveys provide proof of continuity of the beds over large distances. These seismic coverage areas outside of drill hole coverage are considered resources. We have over 50 years of experience determining reserve and resource areas, as well as avoiding anomalous geology. The potash is mined on one level, and we are always able to mine within the appropriate grade range required for the production of potash fertilizer with minimal waste created. Due to the extensive nature of the beds, and relatively consistent grades, the calculation of a cutoff grade is not necessary.

Mosaic’s Phosphate segment is vertically integrated. The phosphate mined is used internally for the manufacture of phosphate fertilizers and animal feed ingredients. Therefore, the determination of phosphate rock value is not as straightforward as, for example, a base metal. In that case a clearer connection exists between cutoff grade and mineral price assumptions. Consistent with other past and present producers in Florida, Mosaic reports reserves on a product or beneficiated basis and not in-situ as substantial amounts of phosphate exist within the finest size fractions and, when beneficiated, are lost in waste streams. This methodology is consistent with over 30 years of US Geological Survey reporting. Reserve determinations are not solely based on the concentration of phosphate. Impurities such as MgO, Fe2O3 and Al2O3 exist in phosphate rock and, in high enough concentrations, are detrimental to the fertilizer manufacturing process. As such, even areas of high phosphate concentration can be deemed unminable if these impurities exceed certain thresholds. Other factors including mining depth, stripping ratio and accessibility are also considered in the reserving process.

fertilizer products is met. Mosaic Fertilizantes’ Potash mine also uses a cutoff grade that was adopted as a minimum feed grade required to manufacture fertilizer products. Therefore, in future Form 10-K filings we will include in the Mosaic Fertilizantes Segment under the reserve table on page 20, footnote (d) that notes phosphates cutoff grades and on page 21, under the discussion of Reserves related to the potash mine the potash cutoff grade, as shown in the response to question number 3 below.

On June 16, 2020, we advised the Staff in a telephone conversation with John Coleman, George Schuler, and Craig Arakawa, that the Company will submit to the Staff the requested supplemental information on or before June 23, 2020. We hereby inform the Staff that on June 23, 2020 we provided to Messrs. Coleman, Schuler and Arakawa the requested supplemental information through access to a secure data site pursuant to Rule 12b-4 of Regulation 12B under the Securities Exchange Act of 1934, as amended.

For technical questions concerning Mosaic Fertilizantes reserves please call Brian Ball, Director Mine Strategy – North America Operations, who can be reached at 863-559-2021.

The Company acknowledges the Staff’s comment and in accordance with paragraph (b) (5) of Industry Guide 7, in future Form 10-K filings we will include in the Mosaic Fertilizantes Segment under the reserve table on page 20, footnote (c) that separates our proven and probable phosphates reserves as noted below. This treatment is similar to how it is reported for the Phosphates and Potash segments. Revised material or additions to the current material are italicized.

As disclosed on page F-45 in Note 1 to our consolidated financial statements included in our Form 10-K, Mosaic is a member of Canpotex Limited (“Canpotex”), who is in the business of purchasing Potash from its two Canadian Potash producing members and selling such Potash for export to destinations outside the United States and Canada. Canpotex is a stand-alone entity with its own assets and employees.

Our 36.2% membership interest in Canpotex provides us with the ability to exercise significant influence over the operating and financial decisions of the business. As such, we apply the equity method of accounting under ASC 323 to account for our investment. The design of Canpotex, however, is to break even and therefore the carrying value of Mosaic’s investment balance and equity earnings or loss is immaterial.

As a member company, we sell Canadian sourced potash to Canpotex. In accordance with ASC 606 and ASC 323, we recognize revenue from these sales upon delivery by Canpotex to the unrelated third party customer. Sales of potash to Canpotex, once delivered to the unrelated third party customer, are recognized as a component of Net Sales within our Consolidated Statements of Earnings.

To clarify our accounting policies related to our equity investment in Canpotex, in future Form 10-K filings we will expand the disclosure in the note discussing Investments in Non-Consolidated Companies to include the following statement:

We will also be more descriptive of how we record sales to Canpotex and expand the disclosure in the note discussing Business Segments to read as follows: