SecProbe.io

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VIA FACSIMILE AND U.S. MAIL

September 1, 2005

Rustom Jilla
Chief Financial Officer
Ansell Limited
Level 3, 678 Victoria Street
Richmond, Victoria, 3121 Australia

	RE:	Form 20-F for Fiscal Year Ended June 30, 2004
      File No. 0-15850

Dear Mr. Jilla:

		We have reviewed these filings and have the following
comments.  If you disagree with a comment, we will consider your
explanation as to why our comment is inapplicable or a revision is
unnecessary.  Please be as detailed as necessary in your
explanation.
In some of our comments, we may ask you to provide us with
information
so we may better understand your disclosure.  After reviewing this
information, we may or may not raise additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We
look forward to working with you in these respects.  We welcome
any
questions you may have about our comments or on any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

FORM 20-F FOR FISCAL YEAR ENDED JUNE 30, 2004

General

1. Where a comment below requests additional disclosures or other
revisions to be made, please show us in your supplemental response
what the revisions will look like.  With the exception of the
comments
below that specifically request an amendment, all other revisions
may
be included in your future filings.  If your accounting under
Australian GAAP differs from your accounting under US GAAP, please
also show us the additional disclosures that will be included in
your
US GAAP reconciliation footnote.

Item 5 - Operating and Financial Review and Prospects

Results of Operations, page 19

2. You discuss the business reasons for changes between periods in
your financial statement line items.  However, in certain
circumstances where there is more than one business reason for the
change, you should quantify the incremental impact of each
individual
business reason discussed on the overall change in the line item
if
possible.  Please quantify each business reason where practical.
Please also disclose the impact of foreign currency fluctuations
on
your results, if material, as required by Item 5.A.3 of Form 20-F.

Contractual and Commercial Commitments, page 26

3. Please revise your table of contractual cash obligations to
include
estimated interest payments on your debt, planned funding of
pension
benefit obligations and estimated payments under your interest
rate
swaps and foreign currency contracts.  Because the table is aimed
at
increasing transparency of cash flow, we believe these payments
should
be included in the table.  Please also disclose any assumptions
you
made to derive these amounts.

Item 15 - Controls and Procedures, page 80

4. Please amend your Form 20-F for the year ended June 30, 2004 to
disclose the conclusions of your principal executive and principal
financial officers regarding the effectiveness of your disclosure
controls and procedures as of the end of the period covered by the
report.  Please also disclose any changes in your internal
controls
over financial reporting identified in connection with the
evaluation
of your controls and procedures. See Item 15 of Form 20-F.

Financial Statements

Note 36 - Environmental Matters, page 121

5. We remind you that a statement that a contingency is not
expected
to be material does not satisfy the requirements of SFAS 5 if
there is
a reasonable possibility that a loss exceeding amounts already
recognized may have been incurred and the amount of that
additional
loss would be material.  In that case, you should either disclose
the
estimated additional loss or range of loss that is reasonably
possible, or state that such an estimate cannot be made.  Refer to
Question 2 of SAB Topic 5:Y.  Please also provide the additional
disclosures called for by SAB Topic 5:Y.

Note 39 - Major Differences Between Australian GAAP and US GAAP -
Restated

Restatement of prior year US GAAP results, page 127

6. You indicate that the $25 million supply agreement revenue
under
AGAAP in 2001 should have been recorded by SPT in 2002 as a
capital
contribution from Goodyear. Please tell us more about this
restatement
including how you determined this transaction resulted in an
increase
to your share of SPT`s losses in 2001 and a reduction in your
share of
SPT`s losses in 2002.  Please also provide supporting accounting
literature for your conclusion.

(c) - Provisions, page 127

7. The provisions of EITF 94-3 have been nullified by SFAS 146.
Please disclose and tell us whether the requirements of SFAS 146
create a difference between Australian GAAP and US GAAP as well as
how
these differences have been reflected in your reconciliation to US
GAAP.

SOUTH PACIFIC TYRES FINANCIAL STATEMENTS FOR THE YEAR ENDED JUNE
30,
2004

General

8. Please address the comments above in your South Pacific Tyres
financial statements as well.

Note 32 - Major differences between Australian GAAP and US GAAP

(r) Securitisation, page 179

9. You indicated that your securitisation program did not meet the
criteria for off balance treatment.  As a result, all eligible
receivables that are transferred are treated as secured
borrowings.
Please tell us how the cash flows related to these secured
borrowings
are reflected on your statement of cash flows.  Specifically
address
whether the cash flows are reflected in cash flows from operating,
investing, or financing activities and whether the cash receipts
and
payments are reflected on a gross basis.  Please also tell us how
your
presentation of these amounts complies with SFAS 95.

10. Please disclose the amount of receivables at June 30, 2004 and
2003 that serve as collateral as required by paragraph 17(a)(2) of
SFAS 140.

*    *    *    *

		Please respond to these comments within 10 business
days, or
tell us when you will provide us with a response.  Please provide
us
with a response letter that keys your responses to our comments
and
provides any requested information.  Detailed letters greatly
facilitate our review.  Please file your response on EDGAR as a
correspondence file.  Please understand that we may have
additional
comments after reviewing your responses to our comments.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing
includes all information required under the Securities Exchange
Act of
1934 and that they have provided all information investors require
for
an informed investment decision.  Since the company and its
management
are in possession of all facts relating to a company`s disclosure,
they are responsible for the accuracy and adequacy of the
disclosures
they have made.

	In connection with responding to our comments, please
provide, in
writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in their filings;
* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and
* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal
securities laws of the United States.

	In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division
of Corporation Finance in our review of your filing or in response
to
our comments on your filing.

      You may contact Ernest Greene, Staff Accountant, at (202)
551-
3733, or in his absence, Nudrat Salik, at (202) 551-3692, if you
have
questions regarding comments on the financial statements and
related
matters.

						Sincerely,

								Rufus Decker
      							Accounting Branch Chief

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Mr. Rustom Jilla
September 1, 2005
Page 1

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

         DIVISION OF
CORPORATION FINANCE

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