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CORRESP

 May 20, 2013

 VIA EDGAR AND OVERNIGHT MAIL

 United States Securities and Exchange Commission

 Division of Corporate Finance

 100 F
Street N.E.

 Washington, D.C. 20549-8561

 Attn: Mr. Jim B. Rosenberg, Senior Assistant Chief Accountant

Re:
BioMarin Pharmaceutical Inc.

Form 10-K for the Fiscal Year Ended December 31, 2012

 Filed February 26, 2013

 Form 10-Q for the Quarterly Period Ended
March 31, 2013

 Filed April 29, 2013

 File No. 000-26727

 Dear Mr. Rosenberg,

This letter is being submitted in response to comments received from the staff (the “Staff”) of the United States Securities and
Exchange Commission (the “Commission”) by letter dated May 8, 2013, addressed to Daniel Spiegelman, Executive Vice President, Chief Financial Officer of BioMarin Pharmaceutical Inc. (“we”, “our” or the
“Company”) with respect to the Annual Report on Form 10-K for the fiscal year ended December 31, 2012 filed by the Company with the Commission on February 26, 2013 (“2012 Annual Report”) and the Quarterly Report on Form
10-Q for the quarterly period ended March 31, 2013 filed by the Company with the Commission on April 29, 2013 (March 2013 Quarterly Report). The number of the paragraphs below corresponds to the numbering in the comment letter, the text of
which is incorporated into this response letter for convenience.

 STAFF COMMENTS AND COMPANY RESPONSES

Form 10-Q for the Quarterly Period ended March 31, 2013

 Notes to the Consolidated Financial Statements

 Note 10. Inventory, page 11

1.
Please provide us proposed revised disclosure to be included in future periodic reports indicating revisions to your accounting policy regarding capitalization of
inventory costs prior to regulatory approval that specifically states the point during the FDA approval process that you determine a probable future benefit exists and the status of the FDA’s consideration of the safety and efficacy of the
drug/system and evaluation of the manufacturing process at that point. Disclose how you apply the lower of cost or market principle to your pre-launch inventory.

 105 Digital
Drive    .    Novato, CA 94949    .    Tel 415.506.6700    .    Fax
415.382.7889    .    www.BMRN.com

 Response:

 The Company proposes to include disclosures substantially similar to the following in future periodic reports for our accounting policy regarding capitalization of inventory costs prior to regulatory
approval:

 Management’s Discussion and Analysis of Financial Condition and Results of Operations

Critical Accounting Policies and Estimates

 Inventory

 We value inventory at the lower of cost or net
realizable value and determine the cost of inventory using the average-cost method. Inventories consist of currently marketed products and may contain certain products awaiting regulatory approval. In evaluating the recoverability of inventories
produced in preparation for product launches, we consider the likelihood that revenue will be obtained from the future sale of the related inventory together with the status of the product within the regulatory approval process.

We analyze our inventory levels quarterly and write down inventory that has become obsolete, or has a cost basis in excess
of its expected net realizable value and inventory quantities in excess of expected requirements. In applying the lower of cost or net realizable value to pre-launch inventory, we estimate a range of likely commercial prices based on our comparable
commercial products. Expired inventory is disposed of and the related costs are recognized as Cost of Sales in the Consolidated Statements of Operations.

 Inventories Produced in Preparation for Product Launches

We capitalize inventories produced in preparation for product launches sufficient to support estimated initial market
demand. Typically, capitalization of such inventory begins when positive results have been obtained for the clinical trials that we believe are necessary to support regulatory approval, uncertainties regarding ultimate regulatory approval have been
significantly reduced and we have determined it is probable that these capitalized costs will provide future economic benefit in excess of capitalized costs. The factors considered by us in evaluating these uncertainties include the receipt and
analysis of positive Phase III clinical trial results for the underlying product candidate, results from meetings with the relevant regulatory authorities prior to the filing of regulatory applications, and the compilation of the regulatory
application. We closely monitor the status of each respective product within the regulatory approval process, including all relevant communication with regulatory authorities. We also consider our historical experience with manufacturing and
commercializing similar products and the relevant product candidate. If we are aware of any specific material risks or contingencies other than the normal regulatory review and approval process or if there are any specific issues identified relating
to safety, efficacy, manufacturing, marketing or labeling, the related inventory would generally not be capitalized.

 For inventories that are capitalized in preparation of product launch, anticipated future sales, expected approval date and shelf lives are evaluated in assessing realizability. The shelf life of a
product is determined as part of the regulatory approval process; however in evaluating whether to capitalize pre-launch inventory production costs, we consider the product stability data of all of the pre-approval production to date to determine
whether there is adequate expected shelf life for the capitalized pre-launch production costs.

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 NOTES TO CONSOLIDATED FINANCIAL STATEMENTS

NOTE 3 - SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES

 Inventory

 The Company values inventory at the lower of
cost or net realizable value and determines the cost of inventory using the average-cost method. Inventories consist of currently marketed products and may contain certain products awaiting regulatory approval. In evaluating the recoverability of
inventories produced in preparation for product launches, the Company considers the likelihood that revenue will be obtained from the future sale of the related inventory together with the status of the product within the regulatory approval
process.

 The Company analyzes its inventory levels quarterly and writes down inventory that has become
obsolete, or has a cost basis in excess of its expected net realizable value and inventory quantities in excess of expected requirements. In applying the lower of cost or net realizable value to pre-launch inventory, the Company estimates a range of
likely commercial prices based on its comparable commercial products. Expired inventory is disposed of and the related costs are recognized as Cost of Sales in the Consolidated Statements of Operations.

Inventories Produced in Preparation for Product Launches

The Company capitalizes inventories produced in preparation for product launches sufficient to support estimated initial
market demand. Typically, capitalization of such inventory begins when positive results have been obtained for the clinical trials that the Company believes are necessary to support regulatory approval, uncertainties regarding ultimate regulatory
approval have been significantly reduced and the Company has determined it is probable that these capitalized costs will provide some future economic benefit in excess of capitalized costs. The material factors considered by the Company in
evaluating these uncertainties include the receipt and analysis of positive Phase III clinical trial results for the underlying product candidate, results from meetings with the relevant regulatory authorities prior to the filing of regulatory
applications, and the compilation of the regulatory application. The Company closely monitors the status of each respective product within the regulatory approval process, including all relevant communication with regulatory authorities. The Company
also considers its historical experience with manufacturing and commercializing similar products and the relevant product candidate. If the Company is aware of any specific material risks or contingencies other than the normal regulatory review and
approval process or if there are any specific issues identified relating to safety, efficacy, manufacturing, marketing or labeling, the related inventory would generally not be capitalized.

For inventories that are capitalized in preparation of product launch, anticipated future sales, expected approval date
and shelf lives are evaluated in assessing realizability. The shelf life of a product is determined as part of the regulatory approval process; however in evaluating whether to capitalize pre-launch inventory production costs, the Company considers
the product stability data of all of the pre-approval production to date to determine whether there is adequate expected shelf life for the capitalized pre-launch production costs.

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 Note 10 – INVENTORY

Inventory consisted of the following:

March 31,

December 31,

2013

2012

 Raw materials

$
13,314

$
11,943

 Work-in process

75,543

71,443

 Finished goods

46,965

45,309

 Total inventory

$
135,822

$
128,695

 Inventory as of March 31, 2013 and December 31, 2012 included $5.1 million and
$0, respectively, of raw materials purchased for use in the pre-launch Vimizim manufacturing campaign. The Company believes that all material uncertainties related to the ultimate regulatory approval of Vimizim for commercial sale have been
significantly reduced based on positive data from Phase III clinical trial results, successful pre-filing meetings with the Food and Drug Administration (FDA) for the Biologics License Application (BLA), the filing of the BLA with the FDA in the
first quarter of 2013, and the filing of the Marketing Authorization Application (MAA) filed with the European Medicines Agency (EMA) in April 2013. In its evaluation, the Company also considered its historical experience with developing and
commercially producing similar products.

 Inventory as of March 31, 2013 and December 31, 2012 also
included $7.4 million and $12.0 million, respectively, of product manufactured using certain process and specification changes that have not yet received regulatory approval. Although the products have been approved by various regulatory agencies,
the process and specification changes must also be approved before product produced with the alternate processes and specifications can be sold commercially.

 The Company expects to receive regulatory approval and has determined that it is probable that the Company will realize the future economic benefit associated with the costs of these inventories through
future sales.

2.
In addition, please provide us proposed revised disclosure to be included in future periodic reports that discusses the overall FDA approval process; the
description should meaningfully relate to your accounting policy for pre-launch inventory. For each product with significant costs capitalized in inventory prior to the regulatory approval, discuss the following:

•

 The current status of the approval process, including any contingencies needed to be resolved prior to obtaining FDA approval, the
risks affecting the probability of obtaining FDA approval, and the estimated timing of obtaining approval.

•

 The specific nature of any safety and efficacy, manufacturing, and marketing or labeling issues outstanding and why you do not
believe those issues affect its probable future benefit conclusion.

•

 The remaining shelf life of each product, as of each balance sheet date presented, and why you believe you will be able to realize
the inventory prior to the expiration of the shelf life.

•

 The risks and uncertainties surrounding market acceptance of the product once approved and how this will affect the realization of
the asset.

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 Response:

 The Company has provided a detailed discussion of the FDA approval process included in Item 1 Business, under the caption “FDA Approval Process” on page 10 of the Company’s 2012 Annual
Report. The Company believes this detailed description of the FDA approval process, along with our proposed revised accounting policy disclosures provided in response to Staff Comment 1, provide a meaningful link between the FDA approval process,
timing, and inherent risks to the accounting policy followed by the Company.

 The Company provides the following in response to
each of the bulleted points raised by the Staff above:

•

 The Company believes the proposed revised disclosures of its accounting policies provided in response to Staff Comment 1, as well as additional
proposed disclosures regarding the current status of the regulatory approval of Vimizim in Note 10 above, provide adequate disclosure of the current status of the approval process, including the contingencies needed to be resolved prior to obtaining
FDA approval.

 Additionally, in response to the Staff’s comment regarding risks affecting the
probability of obtaining FDA approval, and the estimated timing of obtaining approval, the Company references the following Risk Factor disclosure in Item 1A, page 37 of our March 2013 Quarterly Report. The Company believes this Risk Factor
disclosure adequately discusses risks and uncertainties affecting the probability of obtaining FDA approval and the estimated timing of obtaining approval.

•

 If we fail to obtain or maintain regulatory approval to commercially market and sell our drugs, or if approval is delayed, we will be unable to
generate revenue from the sale of these products, our potential for generating positive cash flow will be diminished, and the capital necessary to fund our operations will be increased.

We must obtain and maintain regulatory approval to market and sell our drug products in the U.S. and in jurisdictions outside of the U.S.
In the U.S., we must obtain FDA approval for each drug that we intend to commercialize. The FDA approval process is typically lengthy and expensive, and approval is never certain. Products distributed abroad are also subject to government regulation
by international regulatory authorities. Naglazyme, Aldurazyme and Kuvan have received regulatory approval to be commercially marketed and sold in the U.S., EU and other countries. Firdapse has received regulatory approval to be commercially
marketed only in the EU. Although we announced in November 2012 that our Phase 3 study of Vimizim™, an enzyme replacement therapy for patients with MPS IVA (Morquio Syndrome), had met its primary endpoint, Vimizim has not received regulatory
approval in the U.S., EU or any other jurisdiction and may never receive approval. Also, even if we receive priority review timelines from the FDA for Vimizim, there is no assurance that the FDA will comply with such timelines and there may be
delays and ultimately the FDA may decide not to approve Vimizim.

 As part of the recent reauthorization of PDUFA, new
biologics are included in a new product review program intended to enhance FDA-sponsor communications to lead to greater first-cycle approval decisions. As part of this program, applications for new biologics are subject to either a 12-month
standard or 8-month priority

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review period that begins from the date of application submission. However, since this is a new product review program and no products have completed this new review process, the priority review
period may take longer than eight months and the standard review period may take longer than 12 months. Similarly, although the EMA has an accelerated approval process, the timelines mandated by the regulations are subject to the possibility of
substantial delays.

 In addition, the FDA and its international equivalents have substantial discretion over the approval
process for pharmaceutical products. As such, these regu