SecProbe.io

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VIA FACSIMILE AND U.S. MAIL

October 28, 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 your letter dated October 7, 2005 and have
the
following comments.  Where indicated, we think you should revise
your
disclosures in response to these comments.  If you disagree, 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.  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 phone numbers listed
below.

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

Contractual and Commercial Commitments, page 26

2. We have read your response to comment three from our letter
dated
September 1, 2005.  Please revise your table of contractual cash
obligations to include planned funding of pension benefit
obligations
and estimated payments under your interest rate swaps and foreign
currency contracts.  Item 5(F) of Form 20-F requires that you
include
all known contractual obligations.   Your pension benefit
obligations,
interest rate swaps and foreign currency contracts represent known
obligations that will be settled in cash.  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

3. We have read your response to comment four from our letter
dated
September 1, 2005.  Please amend your Form 20-F for the year ended
June 30, 2004 to provide updated certifications in addition to the
disclosures regarding the effectiveness of your disclosure
controls
and procedures and changes in your internal controls over
financial
reporting.  See Rule 12b-15 of the Exchange Act.

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

General

4. 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

5. We have read your response to comment nine from our letter
dated
September 1, 2005.  Given that you are accounting for the transfer
of
eligible receivables as secured borrowings, it is not clear why
you
would not present the cash flows associated with these transfers
as
financing activities based on the guidance provided by paragraph
18 of
SFAS 95.  We remind you that paragraph 22(a) of SFAS 95 refers to
cash
receipts from the sale of accounts receivable.  Please revise the
statement of cash flow information under US GAAP provided in Note
33
to reflect these transfers as cash flows from financing
activities.

FORM 6-K FILED ON OCTOBER 3, 2005

6. You state that a review of the investment in South Pacific
Tyres
indicated that the carrying value, based on its operating
performance
in the second half of the financial year, was in excess of the
estimated worth.  Given that South Pacific Tyres reported net
losses
for each of the three years ended June 30, 2004, please tell us
the
specific facts and circumstances that led you to determine that a
write-down was necessary during the six months ended June 30,
2005.
Please also tell us how you arrived at the amount of the write-
down,
including any significant assumptions and estimates used.

*    *    *    *

		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.

      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
October 28, 2005
Page 1

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

         DIVISION OF
CORPORATION FINANCE

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