Ownership Submission
FORM 3
 UNITED STATES SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549

INITIAL STATEMENT OF BENEFICIAL OWNERSHIP OF SECURITIES

Filed pursuant to Section 16(a) of the Securities Exchange Act of 1934, Section 17(a) of the Public Utility Holding Company Act of 1935 or Section 30(h) of the Investment Company Act of 1940
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(Print or Type Responses)
1. Name and Address of Reporting Person *
  RESPINI LUCIANO
 2. Date of Event Requiring Statement (Month/Day/Year)
11/01/2004		 3. Issuer Name and Ticker or Trading Symbol
DOW CHEMICAL CO /DE/ [DOW]
(Last)
(First)
(Middle)
2030 DOW CENTER		 4. Relationship of Reporting Person(s) to Issuer
(Check all applicable)
_____ Director _____ 10% Owner
__X__ Officer (give title below) _____ Other (specify below)
Corporate Vice Presdient
 5. If Amendment, Date Original Filed(Month/Day/Year)
(Street)

MIDLAND, MI 48674		 6. Individual or Joint/Group Filing(Check Applicable Line)
_X_ Form filed by One Reporting Person
___ Form filed by More than One Reporting Person
(City)
(State)
(Zip)
Table I - Non-Derivative Securities Beneficially Owned
1.Title of Security
(Instr. 4)		 2. Amount of Securities Beneficially Owned
(Instr. 4)		 3. Ownership Form: Direct (D) or Indirect (I)
(Instr. 5)		 4. Nature of Indirect Beneficial Ownership
(Instr. 5)
Common Stock 10,011
D
 

Reminder: Report on a separate line for each class of securities beneficially owned directly or indirectly. SEC 1473 (7-02)
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Table II - Derivative Securities Beneficially Owned (e.g., puts, calls, warrants, options, convertible securities)
1. Title of Derivative Security
(Instr. 4)		 2. Date Exercisable and Expiration Date
(Month/Day/Year)		 3. Title and Amount of Securities Underlying Derivative Security
(Instr. 4)		 4. Conversion or Exercise Price of Derivative Security 5. Ownership Form of Derivative Security: Direct (D) or Indirect (I)
(Instr. 5)		 6. Nature of Indirect Beneficial Ownership
(Instr. 5)
Date Exercisable Expiration Date Title Amount or Number of Shares
Deferred Stock (1)   (2) 02/13/2009 Common Stock 11,120 $ 0 D  
Deferred Stock - Performance Award (1)   (3) 04/16/2007 Common Stock 6,250 $ 0 D  
Deferred Stock - Performance Award (1)   (4) 04/16/2008 Common Stock 6,875 $ 0 D  
Non-Qualified Stock Option (right to buy) (1)   (5) 02/12/2007 Common Stock 36,000 $ 26.6458 D  
Non-Qualified Stock Option (right to buy) (1)   (6) 02/14/2013 Common Stock 45,000 $ 27.4 D  
Non-Qualified Stock Option (right to buy) (1)   (7) 02/15/2012 Common Stock 27,500 $ 30.425 D  
Non-Qualified Stock Option (right to buy) (1)   (8) 02/27/2008 Common Stock 17,100 $ 30.5208 D  
Non-Qualified Stock Option (right to buy) (1)   (9) 02/16/2009 Common Stock 28,500 $ 31.1042 D  
Non-Qualified Stock Option (right to buy) (1)   (10) 03/02/2011 Common Stock 25,000 $ 33.94 D  
Non-Qualified Stock Option (right to buy) (1)   (11) 02/16/2010 Common Stock 66,000 $ 36.0208 D  
Non-Qualified Stock Option (right to buy) (1)   (12) 02/13/2014 Common Stock 33,340 $ 43.49 D  

Reporting Owners

Reporting Owner Name / Address Relationships
Director 10% Owner Officer Other
RESPINI LUCIANO
2030 DOW CENTER
MIDLAND, MI 48674		       Corporate Vice Presdient  

Signatures

Luciano Respini 11/10/2004
**Signature of Reporting Person Date

Explanation of Responses:

* If the form is filed by more than one reporting person, see Instruction 5(b)(v).
** Intentional misstatements or omissions of facts constitute Federal Criminal Violations. See 18 U.S.C. 1001 and 15 U.S.C. 78ff(a).
(1) Granted under The Dow Chemical Company 1988 Award and Option Plan, a Rule 16b-3 plan. The Plan provides for tax withholding rights.
(2) The shares to be delivered in one installment upon vesting on February 13, 2009.
(3) The award vests, if at all, upon the Company's common stock reaching and maintaining a market price of $55 per share for a specified time period before December 31, 2005. Delivery of vested shares will be in two equal installments on April 16, 2006 and April 16, 2007.
(4) The award vests, if at all, upon the Company's common stock reaching and maintaining a market price of $55 per share for a specified time period before December 31, 2006. Delivery of vested shares will be in two equal installments on April 16, 2007 and April 16, 2008.
(5) The options vest in three equal annual installments beginning on February 12, 1998.
(6) The options vest in three equal annual installments beginning on February 14, 2004.
(7) The options vest in three equal annual installments beginning on February 15, 2003.
(8) The options vest in three equal annual installments beginning on February 27, 1999.
(9) The options vest in three equal annual installments beginning on February 16, 2000.
(10) The options vest in three equal annual installments beginning on March 2, 2002.
(11) The options vest in three equal annual installments beginning on February 16, 2001.
(12) The options vest in three equal annual installments beginning on February 13, 2005.

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