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Correspondence Letter

 October 7, 2005

 Via EDGAR

 Mr. Rufus Decker

 Accounting Branch Chief

 United States Securities and Exchange Commission

 Washington, D.C. 20549-7010

Re:
Ansell Limited

 Form 20-F for the Fiscal Year
Ended June 30, 2004

 File No. 0-15850

 Dear Mr. Decker:

 This is in response to your letter of September 1, 2005.

 I have attached our responses to the questions raised following your review of our Form 20-F
for the Fiscal Year ended 30 June 2004. For your convenience, I have included the text of the Staff’s comments at the beginning of each of our responses. It is our intention to file an amendment to our Form 20-F to incorporate disclosures
in respect of Item 15 – Controls and Procedures.

 In responding to your comments Ansell Limited acknowledges 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 proceedings initiated by the Commission or any person under the federal securities laws of the United States.

Sincerely

 /s/ Rustom Jilla

Rustom Jilla

Chief Financial Officer

cc:
Ernest Greene

 Nudrat Salik

 Responses to SEC Comments on Ansell Limited’s Form 20F for Fiscal Year Ended June 30, 2004

 Item 5 – Operating and Financial Review and Prospects

 2. Results of Operations, page 19

 You discuss the business reasons for changes between periods in your financial statements
line items. However, 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 in 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.

 Response

 Your comments are noted. Where practical we will incorporate in our future filings the
additional information you have indicated should be disclosed in our review of our operating results. However we advise the Staff that in many instances it is not possible to separately or accurately determine or quantify the effect of each of the
various components that account for a change in a respective line item because the various parts of our operations are often impacted by multiple factors which we do not quantitatively track.

 In respect of the review of the operating results of Ansell Healthcare for the year ended
June 2004 compared to June 2003 the following additional/supplementary information [ in italics ] is provided.

 Ansell Healthcare’s sales of $1,113.3 million were 13.9% lower than the previous year while operating profit of $146.3 million was 8.3% lower. Sales and operating profit were both materially impacted by currency
movements compared to the prior period.

 The United States dollar [ USD ] is
the predominant global currency of our business transactions however sales and operating profits are reported in Australian dollars [ AUD ] in compliance with the reporting requirements of the Australian Corporations Act 2001 and Australian
Accounting Standards. Translation of sales and operating profit from USD to AUD is based on average exchange rates prevailing over the reporting period. Over the course of the 2004 year the average USD/AUD exchange rate was 0.70160 compared to
0.58651 for the 2003 year. This difference in the average USD/AUD exchange rates materially impacted the value of reported 2004 AUD sales compared to 2003.

 Occupational Healthcare

Sales of $545.3 million were lower than the previous year by 12.9% while operating profit of $74.2 million was higher by 18.0%. Operating profit margin increased from
10.1% to 13.6%.

 This segment accounted for
approximately 49% of Ansell Healthcare’s total revenues and 51% of operating profit.

 The expanding HyFlex® family of products continued to drive sales with substantial year on year growth in volume of 19% and in value $3.8 million. Sales of knitted gloves finished the year down 17.9%. Sales of
Chemical Resistant Gloves declined by 15.8% and sales of remaining product categories were lower by 15.0%. However, continued margin gains due to positive sales mix and some volume gains drove the operating profit improvement. The knitting plant in
North Carolina, USA was closed and the Mexican knitting plant had significantly improved results due to this consolidation and improved production process.

Benefits also began to flow from our growing and innovative proprietary selling program – Ansell Value Proposition in North America.

 Professional Healthcare

 Sales of $381.8 million were lower than the prior period by 15.6% while operating profit of $40.5 million was lower by 24.9%. Operating
profit margin decreased from 11.9% to 10.6%.

 This segment accounted for approximately 34% of Ansell Healthcare’s revenue and 27% of operating profit.

 Sales of surgical gloves declined by $46.5 million or 18.3% and examination gloves by $23.6 million or 13.2%. In the USA, surgical market share recovery was slower
than expected, though the signing of 5 large Group Purchasing Organization (GPO) contracts should help in the future. Surgical glove volumes in Europe were lower following a strategic decision to reduce our reliance on private label customers in
favor of sales of Ansell branded product. Sales of examination gloves in Europe improved in the second half of the year as prices were adjusted to meet the competitive environment created by a stronger Euro. Global competitive price pressures for
examination gloves and latex cost increases adversely impacted profitability.

 Consumer Healthcare

 Sales of $186.3 million were lower than
the prior period by 13.8%, while operating profit of $31.6 million was lower by 26.2%. Operating profit margin decreased from 19.8% to 17.0%.

 This segment accounted for approximately 17% of Ansell Healthcare’s revenues and 22% of operating profit.

 Sales of condoms declined by $18.9 million or 11.5%. Condom volumes increased by 7% year on year primarily due to bid
contracts in both Brazil and India. Retail results were adversely impacted by new retail entrants and heightened competition in several major markets that adversely impacted sales growth and caused additional selling / advertising expenses. Sales in
other product categories declined by $10.8 million or 20.7%. Household glove sales in the second half of the year were below the same period in the prior year primarily due to reductions and clearances of older technology products in anticipation of
deliveries in the coming year of Ansell’s new Foamlined gloves.

 3. Contractual and Commercial Commitments, page 26

 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 swaps and foreign
currency contracts. Because the table is aimed at increasing transparency of cash flow, we believe those payments should be included in the table. Please also disclose any assumptions you made to derive these amounts.

 Response

 We advise the Staff that in preparing the table of contractual cash obligations required by
Item 5F, particular attention was paid to the instructions to the Form 20-F for Item 5F and the desire to enable users to reconcile the values included in this table with the total of Non-Current Liabilities reflected on the Company’s
Balance Sheet as at 30 June 2004 (excluding Operating Lease obligations which are not reflected on the Balance Sheet under Australian GAAP).

 In future filings, we will include estimated interest payments on our debt portfolio in the table of contractual commitments with appropriate footnote disclosure as to
the potential variability in such amounts due to the portfolio mix between fixed and floating rate debt.

 The Company is not clear as to why planned funding of pension benefit obligations and payments under interest rate swaps and foreign currency contracts would need to be included pursuant to the instructions of
Item 5F.

 As at 30 June 2004 pension benefit obligations and amounts
payable under interest rate swaps and foreign currency contracts were not reflected within Long-Term Liabilities on the A GAAP Balance Sheet

 In future filings the company will make reference to Note 27 of the Consolidated Financial Statements as disclosed under Item 18 which provides detailed information
in respect of the derivative financial instruments used by the consolidated entity, such as foreign exchange and interest rate swaps and the consolidated entity’s exposure to interest rate risk.

 4. Item 15 – Controls and Procedures, page 80

 Please amend your Form 20-F for the year ended June 30, 2004 to disclose the
conclusions of your principal financial officer 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.

 Response

 The Form 20-F for the year ended June 30, 2004 is being amended to include the following additional disclosure.

 Evaluation of Disclosure Controls and Procedures

 The Company carried out an evaluation, under the supervision and with the participation of
the Company’s management, including the Chief Executive Officer and the Chief Financial Officer, of the effectiveness of the design and operation of its disclosure controls and procedures. Disclosure controls and procedures are designed to
ensure that the material financial and non-financial information required to be disclosed in the Form 20-F and filed with the Securities and Exchange Commission is recorded, processed, summarized and reported in a timely manner.

 Based on this evaluation, the Company’s management, including the Chief Executive
Officer and the Chief Financial Officer, concluded that the Company’s disclosure controls and procedures were effective as of the end of the period covered by this report.

 Internal Controls

 There have been no changes in the Company’s internal control over financial reporting during the period covered by this report that have materially affected, or are
reasonably likely to materially affect, the Company’s internal control over financial reporting.

 Financial Statements

 5. Note 36 – Environmental Matters, page 121

 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 the 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.

 Response

 We acknowledge your comments. We will amend the wording of the Note in future filings as follows:

 The Company and various Group Companies as the occupiers of property receive,
from time to time, notices from relevant authorities pursuant to various environmental legislation. On receiving such notices, the Company evaluates potential remediation options and the associated costs. At this time, the Company does not believe
that the potential financial impact of such remediation upon the economic entity can be reliably measured.

 Note 39 - Major Differences between Australian GAAP and US GAAP – Restated

 6. Restatement of prior year US GAAP result, page
127

 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

 Response

 The restatement for the accounting treatment adopted for the $25m MRT Supply Agreement revenue is summarized as follows:

 Background

 In late calendar year 2000, South Pacific Tyres (SPT) was a partnership owned 50% indirectly
by the Goodyear Tire & Rubber Company (Goodyear) and 50% by Ansell. In late 2000, SPT’s Medium Radial Tyre (MRT) plant located in Australia was experiencing significant financial difficulties and it was determined by the partners that
SPT would embark on a restructuring plan which would include the closure of the MRT plant, the termination of a significant number of employees, the reduction of debt and other events. The combined cost of the restructuring plan at the time was
estimated by SPT to be approximately $84 million. This amount was agreed to be funded by capital contributions made equally by the respective partners in the combined amount of $28 million with the balance of $56 million being paid by Goodyear
including $25 million to be paid in the form of an up-front fee (the Inducement Payment) in connection with the ongoing sourcing by SPT of MRT tyres from certain other Goodyear tyre manufacturing plants. In spite of the imbalance in funding by the
partners, the respective ownership interests in the partnership by the partners were not affected.

 Contemporaneously with the approval by the partners and commencement of the restructuring plan, SPT entered into two MRT tyre supply agreements with Goodyear. The 2001 Agreement signed on December 29, 2000, was
effective for a two-year period and required SPT to purchase an annual minimum of 150,000 MRT tyres from Goodyear. The 2001 Agreement specified that the price per tyre to be paid by SPT would be equivalent to the market price of a tyre having
similar characteristics and of

 similar quality offered by another supplier. The 2001 Agreement did not preclude SPT from purchasing MRT tyres from
another supplier however; a penalty of US$10 per tyre would be assessed in the event the annual minimum purchase commitment was not met. Conversely, penalty provisions also existed requiring Goodyear to reimburse SPT for lost selling margin in the
event the annual minimum quantity was not made available to SPT. The contract was considered to be at market value considering the pricing terms and the fact that the annual minimum commitment was not assessed as onerous as SPT expected to have an
on going requirement to procure 350,000 to 450,000 MRT tyres per annum to meet its forecasted customer demand.

 The 2003 Agreement, also signed on December 29, 2000, was effective for a ten-year period commencing with the conclusion of the 2001 Agreement. The terms and conditions of the 2003 Agreement were similar to the
2001 Agreement except that the minimum annual commitment was increased to 200,000 MRT tyres, the price per tyre was set using a formula of cost plus 5% subject to Goodyear still being required to match the market price and quality of an equivalent
tyre from another supplier and the inclusion of the $25 million Inducement Payment. Specifically, the contract stated “in the event that SPT is able to demonstrate that in any year tires supplied by Goodyear are not competitive by reason of
price, performance, customer needs and/or market developments then SPT may purchase products from other suppliers as long as tires from Goodyear remain non-competitive with respect to any or all of the factors referred to. Any tires so purchased
from other suppliers will be deducted from the minimum commitment for the particular year in wh