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September  2, 2005

September  2, 2005

Securities and Exchange Commission

Division of Corporation Finance

450 Fifth Street, N.W.

Washington, D.C.  20549-0303

Attention:	Rufus Decker

	Accounting Branch Chief

	Re:	Madeco S.A.

	Form 20-F for the Year Ended December 31, 2004

	File No.1-11870

Dear Mr. Decker:

On behalf of Madeco S.A. (the "Company"), set forth below are responses to the comment letter dated August 8, 2005 (the "Comment Letter") from the staff of the Securities and Exchange Commission (the "SEC" or the "Commission") related to the Company's Form 20-F for the year ended December 31, 2004 (the "Form 20-F").  As requested, this letter is being filed on EDGAR.  Additionally, five copies of this letter are being delivered to you.

All references in the Company's response to pages and captioned sections are to the Form 20-F as originally filed.  Capitalized terms used in this letter and not otherwise defined herein have the meaning as ascribed to them in the Form 20-F.

For convenience, the Company has included the SEC staff's comments in italics below followed by the Company's response.

Form 20-F for the Year ended December 31, 2004

General

1.	Where a comment below requests additional disclosures or other revisions please show us in your response what the revisions will look like.  Such revisions may be included in your future filings.

Where a comment requests additional disclosure, the Company has included the disclosure it would have included in its Form 20-F for year 2004 in this response letter.

Item 3.A. - Key Information  - Selected Financial Data

2.	Please revise your table to include the U.S. GAAP earnings per share information as well as any other items required to be presented in selected financial data under Chilean GAAP if different on a U.S. GAAP basis.  See the minutes to the AICPA International Practices Task Force July 15, 2003 meeting, specifically Agenda Item 12

Response:

The Company has revised the selected financial data table to include the information requested.  In future filings, the Company will disclose the requested additional information, which has been prepared in accordance with U.S. GAAP and presented in millions of constant Chilean pesos as of December 31, 2004.  If the additional information would have been presented in the Company's 20-F report for the year 2004, it would have been as follows:

2000

2001

2002

2003

2004

Income Statement Data (U.S. GAAP)

Net sales

Ch$345,321

Ch$366,968

Ch$261,110

Ch$243,608

Ch$324,035

Operating income (loss)

11,330

(23,686)

(24,189)

(3,501)

21,471

Non-operating income and expenses

(30,469)

(15,732)

(17,109)

(17,218)

(8,662)

Income taxes

(2,485)

(5,942)

2,819

(591)

(2,532)

Net (loss) Income

(28,100)

(58,553)

(45,180)

(20,152)

9,579

Per share (US GAAP)

Number of shares

386,000,000

386,000,000

405,511,028

4,120,088,408

4,441,192,887

Results per share

(70.98)

(145.85)

(115.66)

(7.05)

2.27

Balance Sheet Data (U.S. GAAP)

Total current assets

191,617

159,635

113,232

142,110

146,253

Property, plant and equipment , net

227,595

218,459

198,546

157,970

143,793

Total Assets

493,863

445,012

378,625

347,944

331,531

Total current liabilities

209,509

187,773

108,403

76,410

63,465

Long-term liabilities

100,305

115,322

167,822

127,249

114,213

Total Liabilities

309,814

303,095

276,225

203,659

177,678

Interest Bearing debt

225,556

237,122

231,781

165,321

133,756

Minority interest

14,440

16,261

13,854

10,188

9,936

Total shareholders' equity

169,609

125,656

88,546

134,097

143,918

Liquidity and Capital Resources

Contractual Obligations and Commercial Commitments

3.	Please revise your table of contractual cash obligations to clarify whether you have included estimated interest payments on your debt.  Because the table is aimed at increasing transparency of cash flow, we believe these interest payments should be included in the table.  Please also disclose any assumptions you made to derive estimated interest payments.  If you chose to provide a textual discussion, the discussion should quantify the interest payments using the same time frames as the table Refer to footnote 46 to Release 33-8350.

Response:

The Company has revised the table to include the information requested.  In future filings, the Company will disclose the requested additional information.  If the additional information would have been presented in the Company's 20-F report for the year 2004, it would have been as follows:

Contractual Obligations Due by Period (in Ch$ million)

Contractual Obligations

Total

< 1 year

1-3 years

3-5 years

> 5 years

Short-Term and Long-Term Debt

143,899

51,033

31,218

36,059

25,589

Capital Lease Obligations

6,846

906

1,399

974

3,567

Operating Leases

364

154

210

-

-

Other Long-Term Obligations

2,852

1,829

1,023

-

-

Scheduled interest payment obligations (*)

16,500

4,836

6,639

3,916

1,109

Severance Indemnities

4,997

2,483

967

103

1,444

Total Contractual  Obligations

158,958

56,405

34,817

37,136

30,600

(*) Scheduled interest payments obligations related to long-term obligations were calculated using stated coupon rates for fixed debt and interest rates applicable at December 31, 2004, for variable rate debt.

Critical Accounting Policies

4.	Your reference to your significant accounting policies in your historical financial statements does not provide the level of detail required by SEC Interpretive Release No. 33-8350, SEC Other Release No. 33-8040 and SEC Proposed Release No. 33-8098, all of which you can find on our website at www.sec.gov.  Your critical accounting policies and estimates section should focus on those estimates that are critical to your consolidated financial statements.  The discussion should include a discussion of the material assumptions you made in arriving at the critical estimate and advise an investor of the financial statement impact if actual results differ from the estimate made by management.  Please identify all of your critical policies and estimates and expand your discussion to address the following areas:

Types of assumptions underlying the most significant and subjective estimates;

Sensitivity of those estimates to deviations of actual results from management's assumptions; and

Circumstances that have resulted in revised assumptions in the past.

Response:

The Company's disclosure of  Critical Accounting Policies in its future Form 20-Fs will be revised in accordance with the Commission's comment.  If the requested disclosure would have been presented in the Company's 20-F report for the year 2004, it would have been as follows:

Critical Accounting Policies and Estimates

The Company prepares its consolidated financial statements in conformity with Chilean GAAP and the guidelines issued by the Chilean Superintendency of Securities and Insurance.  The notes to the Consolidated Financial Statements contain a summary of the accounting policies that are significant to the Company, as well as a description of the significant differences between these policies and U.S. GAAP.  The notes include additional disclosures required under U.S. GAAP, a reconciliation between shareholders' equity and net income to the corresponding amounts that would be reported in accordance with U.S. GAAP and a discussion of recently issued accounting pronouncements.

Both Chilean and U.S. GAAP require management to make certain estimates and assumptions, as some of the amounts reported in the financial statements are related to matters that are inherently uncertain.  The Company believes that the following discussion describes those areas that require the most judgment or involve a higher degree of complexity in the application of the accounting policies that currently affect the Company's financial condition and results of operations. The most critical judgments that have a significant impact on the Company's financial statements include: estimates with respect to the extent to which allowances are required for doubtful accounts receivable and inventory obsolescence, estimates involved in impairment testing for property, plant and equipment and goodwill, and the determination as to whether valuation allowances are required against deferred income tax balances.

Allowance for inventory obsolescence

Inventories of finished products, work in progress and by-products are valued at production cost including direct and indirect manufacturing costs plus price-level restatement.  Inventories of goods for resale, raw materials, other materials and materials in transit are valued at price-level restated cost.  The Company regularly reviews inventory quantities on hand and records an allowance for obsolescence based upon inventory turnover, aging, specific physical conditions by type of inventory and current and future expectations related to estimated forecast of product demand and production requirements. To the extent necessary, the Company establishes provisions for obsolescence based on a comparison of the carrying value to  the net realizable value of finished goods and work-in-process, using expected selling prices, as evidenced by sales subsequent to the balance sheet date, customer contracts, and calculations of the cost to complete or dispose of the merchandise.  The Company believes that this accounting estimate is critical because estimates of future product demand may prove to be inaccurate, in which case the Company may have understated or overstated the provision required for excess and obsolete inventory.  In the future, if inventory is determined to be overvalued, the Company would be required to recognize such costs in cost of goods sold at the time of such determination. Likewise, if inventory is determined to be undervalued, the Company may have over-reported costs of goods sold in previous periods and would be required to recognize such additional operating income at the time of sale. Therefore, although the Company periodically reviews the accuracy of its forecasts of future product demand, any significant unanticipated changes in demand or technological developments could have a significant impact on the realizable value of its inventory and reported operating results. During the years ended December 31, 2003 and 2004 the Company sold certain products that were previously subject to the obsolescence provision, due to an increase in demand of certain products of the wire and cable segment and improvements in the inventory administration, which resulted in a lower cost of sales in the amount of ThCh$ 830,395 and ThCh$ 1,182,794 during the years ended December 31, 2003 and 2004, respectively. Inventory values do not exceed their estimated net realizable value.

Property, Plant and Equipment

The Company estimates the useful lives of property and equipment in order to determine the amount of depreciation and amortization expense to be recorded during any reporting period. The estimated useful lives are based on the historical experience with similar assets as well as taking into account anticipated technological or other changes. If technological changes were to occur more rapidly than anticipated or in a different form than anticipated, the useful lives assigned to these assets may need to be accelerated, resulting in the recognition of increased depreciation and amortization expense in future periods.

The Company evaluates the recoverability of its long-lived assets (other than intangibles and deferred tax assets) in accordance with Technical Bulletin No. 33 "Accounting Treatment of Property, Plant and Equipment", issued by the Chilean Association of Accountants, and SFAS No. 144, "Accounting for the Impairment or Disposal of Long-Lived Assets,". Long-lived assets are reviewed for impairment whenever events or changes in circumstances indicate that the carrying amount of an asset may not be recoverable. The rules require recognition of impairment of long-lived assets in the event that the net book value of such assets exceeds the future undiscounted net cash flows attributable to such assets. Impairment, if any, is recognized in the period of identification to the extent the carrying amount of an asset exceeds the fair value of such asset.  While the carrying values of property, plant and equipment may differ under Chilean GAAP and US GAAP, the impairment testing methodology is similar. During the years ended December 31, 2003 and 2004, the Company recorded charges for impairment related to its property, plant and equipment, including those assets which are temporarily inactive and underutilized production facilities, amounting to ThCh$2,848,484 and ThCh$849,861, respectively.

The Company believes that the accounting estimate related to asset impairment is critical because it is highly susceptible to change from period to period and because it requires management to make assumptions about future sales and cost of sales over the estimated life of property, plant and equipment and to estimate the net realizable value of inactive assets classified as held for sale.

Goodwill

The Company has significant intangible assets related to goodwill. Under Chilean GAAP, goodwill should be reviewed for impairment when events or circumstances, such as recurring losses for two or more periods, indicate a possible inability to realize the carrying amount of the asset.  Under US GAAP, goodwill must be allocated to reporting units and tested for impairment at least annually or more frequently if events or circumstances, such as adverse changes in the business climate, indicate that there may be justification for conducting an interim test. While the carrying values of goodwill may differ under Chilean GAAP and US GAAP, the impairment testing methodology is similar.  In general, the impairment testing is performed at the reporting-unit level (which is generally one level below the major business segments of a company). The first part of the test is a comparison, at the reporting unit level, of the fair value of each reporting unit to its carrying amount, including goodwill. If the fair value is less than the carrying value, then the second part of the test is required to measure the amount of potential goodwill impairment. The implied fair value of the reporting unit goodwill is calculated and compared to the carrying amount of goodwill recorded in the Company's financial records. If the carrying value of reporting unit goodwill exceeds the implied fair value of that goodwill, then the Company would recognize an impairment loss in the amount of the difference, which would be recorded as a charge against net income.

The fair values of the reporting units are estimated using discounted cash flow models based on each reporting unit's internal forecasts. The Company develops internal forecasts annually based on recent sales data for existing products, existing sales commitments and operational projections at each segment level.

The Company believes that the accounting estimate related to goodwill impairment is critical because the impairment analysis requires management to make subjective judgments concerning estimates of how the assets will perform in the future.  Additionally, estimated cash flows may extend beyond five years and, by their nature, are difficult to determine.  Events and factors that may significantly affect the estimates include, among others, competitive forces, customer behavior and attrition, changes in revenue growth trends, inflation, cost structures and technology, changes in interest rates, foreign exchange rates and specific industry or market sector conditions. If the Company's future performance differed adversely from management's best estimate of key economic assumptions and the Company's associated cash flows were to materially decrease, the Company could potentially experience future material impairment charges with