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 January 16, 2026

Jason Crawford
Chief Financial Officer
AZZ INC
One Museum Place, Suite 500
3100 West 7th Street
Fort Worth, TX 76107

 Re: AZZ INC
 Form 10-K for the Fiscal Year Ended February 28, 2025
 Form 10-Q for the Fiscal Quarter Ended November 30, 2025
 File No. 001-12777
Dear Jason Crawford:

 We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments.

 Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.

Form 10-Q for the Fiscal Quarter Ended November 30, 2025
Financial Statements for the Nine Months Ended November 30, 2025
Condensed Consolidated Statements of Cash Flows, page 6

1. We note the $273.2 million distribution on investment in AVAIL joint
venture
 classified within operating activities. We further note from your
disclosures in Note 8
 that at the time of this distribution, the amount of the distribution
exceeded your
 investment in the AVAIL JV of $107.4 million, resulting in the reduction
of your
 investment in the AVAIL JV to zero and recognition of the excess amount
of
 distribution as a gain. With a view to clarifying how you determined
that none of this
 distribution amount was a return of your investment in the AVAIL JV that
would be
 classified as an investing activity as contemplated by ASC
230-10-45-12(b), please
 revise your upcoming February 28, 2026 Form 10-K to provide an
accounting policy
 clarifying whether you have elected to follow the cumulative earnings
approach or the
 nature of the distribution approach when determining the classification
of distributions
 January 16, 2026
Page 2

 received from equity method investees, and provide similar information
to us in your
 response. Refer to ASC 230-10-45-21D.
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Results of Operations, page 31

2. We note that when analyzing the change in revenue for each of your
segments, you
 indicate the change resulted from a change in volume, partially offset
by a change in
 selling price. While you have provided management's perspective on the
underlying
 factors contributing to the change in selling price, you have not
provided similar
 insight from management into the underlying factors contributing to the
change in
 volume. We further note that management appears to have insight into
these
 underlying factors based on the disaggregation of revenue by end market
provided in
 Note 5 and the discussion in your third quarter earnings call of strong
demand from
 infrastructure projects. Please revise your analysis of changes in
revenue in your
 upcoming February 28, 2026 Form 10-K to provide management's insight
into the
 underlying factors contributing to changes in volume, in addition to
those contributing
 to changes in selling price. Refer to Item 303 of Regulation S-K and SEC
Release No.
 33-8350.
 In closing, we remind you that the company and its management are
responsible for
the accuracy and adequacy of their disclosures, notwithstanding any review,
comments,
action or absence of action by the staff.

 Please contact SiSi Cheng at 202-551-5004 or Jennifer Thompson at
202-551-3737
with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Manufacturing
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