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James Hardie Industries N.V.

Atrium 8th Floor

Strawinskylaan 3077

1077 ZX Amsterdam

The Netherlands

February 29, 2008

VIA EDGAR AND OVERNIGHT DELIVERY

Securities and Exchange Commission

Division of Corporation Finance

100 F Street

N.E., Stop 7010

Washington D.C. 20549

Attention: Mr. Rufus Decker

    Re:

    James Hardie Industries N.V.

File No. 1-15240

Form 20-F for the fiscal year ended March 31, 2007

Dear Mr. Decker,

Transmitted herewith are the responses of James Hardie Industries N.V. (the “Company”) to the
Staff’s comment letter dated January 31, 2008 (the “Comment Letter”) regarding the Company’s Annual
Report on Form 20-F for the fiscal year ended March 31, 2007 (the “20-F”). For ease of reference,
the Company has reproduced the comments set forth in the Comment Letter, as numbered, before each
of its responses below. Unless otherwise noted, page numbers included herein are page references
to the Company’s 20-F, and capitalized terms used, but not defined, herein have the same meanings
attributed to such terms in the 20-F. Courtesy copies of this letter are being delivered to
Brigitte Lippmann, Pamela Long, Ernest Greene and Jeanne Baker.

Securities and Exchange Commission

Page 2

Risk Factors — Page 6

    1.

    In future filings, please provide the information investors need to assess the magnitude of
the risk. For example, to the extent material to understanding the magnitude of the risk,
provide the following quantitative information:

    •

    Quantify the payments to the special purpose fund that provides compensation for
Australian asbestos-related personal injury claims against former companies of the
James Hardie Group.

    •

    Quantify your indemnification obligations to the buyer of your former Gypsum
manufacturing facilities for asbestos-related claims.

    •

    Quantify your indemnification obligations for costs, penalties, fees and
expenses incurred by current or former directors, officers or employees of the
James Hardie Group.

    •

    Quantify your reserves for warranty-related claims and legal proceedings.

    In future filings, to the extent the Company can quantify the risks referenced in the
Staff’s comment and such risks are material, it will include quantitative information in its
risk factor disclosures concerning such risks to the extent such matters are referenced in
its risk factor disclosures. The Company notes, however, that certain risks, such as the
exact amount of any specific future payments to the special purpose fund, beyond the
following fiscal year, cannot be quantified, as such amounts are dependent on a variety of
contingent factors, including the Company’s free cash flow (defined as cash from operations
in accordance with GAAP in force at the date of the Original Final Funding Agreement),
actuarial estimations, actual claims paid, operating expenses of the special purpose fund,
the exchange rate between the Australian dollar and the U.S. dollar and the annual cash flow
cap. See Item 4, “Information on the Company — Legal Proceedings” in the 20-F for an
explanation of these contingent factors. The Company will, however, in future filings
include in its asbestos risk factor disclosure quantitative information about the
anticipated payment to the special purpose fund for the following fiscal year, past payments
to the special purpose fund and the total asbestos liability as of the reported period end.
Similarly, due to the contingent nature of the amounts, the Company also cannot quantify any
future indemnification obligations for costs, penalties, fees and expenses incurred by
current or former directors, officers or employees of the James Hardie Group.

Item 5 — Operating and Financial Review and Prospects — Page 47

Year ended March 31, 2007 Compared to Year Ended March 31, 2006 — Page 52

    2.

    We note that you discuss the changes in net sales in Australian dollars in a more
comprehensive manner that your discussion of changes in your US dollar sales. For example,
you indicate that net sales for your Asia Pacific Fiber Cement segment increased 4% from
$241.8 million in fiscal 2006 to $251.7 million in fiscal year without addressing the reasons
for increase in US dollar sales of 4%. You do, however, disclose that in your Asia Pacific
Fiber Cement segment, net sales in Australian dollars increased 2% due to a 6% increase in
sales volume from 368.3 million square feet to 390.8 million square feet, partly offset by a
3% decrease in the average Australian dollar net sales

Securities and Exchange Commission

Page 3

    price. Please revise to adequately discuss and quantify the reasons for the changes in your
US dollar sales.

    The difference between the increase in U.S. dollars of 4% compared to the increase in
Australian dollars of 2% for the Company’s Asia Pacific Fiber Cement Net Sales is, as
disclosed, entirely due to the change in the Australian dollar to U.S. dollar exchange rate.

    This currency related difference between the U.S. dollar and Australian dollar amounts is
described in the Company’s summary of Total Net Sales which precedes the referenced
disclosure. See the first paragraph on page 52 which states: “Net sales from Asia Pacific
Fiber Cement increased 4% from $241.8 million in fiscal year 2006 to $251.7 million in
fiscal year 2007 due to increased sales volumes and favorable currency exchange rate
differences, partially offset by a decreased average net sales price.”

Controls and Procedures — Page 118

    3.

    We note your disclosure that controls and procedures can provide only ‘reasonable assurance’
regarding management’s control objectives. Please confirm to us, and revise future filings to
clarify, if true, that your officers concluded that your disclosure controls and procedures
are effective at the reasonable assurance level.

    Based on the Company’s evaluation as of March 31, 2007 of the effectiveness of the design
and operations of its disclosure controls and procedures, the Company confirms that its
certifying officers concluded that its disclosure controls and procedures were effective at
the reasonable assurance level as of March 31, 2007, to ensure that the information required
to be disclosed in the reports the Company files or submits under the Exchange Act were
recorded, processed, summarized and reported within the time periods specified in the rules
and forms of the SEC and that such information was accumulated and communicated to the
Company’s management, including the Company’s Chief Executive Officer and Chief Financial
Officer, to allow for timely decisions regarding required disclosures.

    Assuming that the Company’s certifying officers reach similar conclusions from an evaluation
of its disclosure controls and procedures as of the end of the period covered in any future
filing, it will state in such filing that its certifying officers concluded that its
disclosure controls and procedures were effective at the reasonable assurance level as of
the end of such period to ensure that the information required to be disclosed in the
reports the Company files or submits under the Exchange Act were recorded, processed,
summarized and reported within the time periods specified in the rules and forms of the SEC
and that such information was accumulated and communicated to the Company’s management,
including the Company’s Chief Executive Officer and Chief Financial Officer, to allow for
timely decisions regarding required disclosures.

Commitment to Provide Funding on a Long-term Basis in Respect of Asbestos-Related Liabilities
of Former Subsidiaries — Page F-20

    4.

    On page F-21, you indicate that as of March 31, 2007, the undiscounted value of the central
estimate of the asbestos-related liabilities of Amaca and Amaba as determined by

Securities and Exchange Commission

Page 4

    KPMG Actuaries was approximately $2.3 billion. You further indicate that this central
estimate was calculated in accordance with Australian Actuarial Standards, which differ from
accounting principles generally accepted in the United States of America and that this
undiscounted central estimate is net of expected insurance recoveries of $393 million. You
also indicate that the undiscounted range of potential costs was $1.3 billion to $4.1
billion. We assume that, based on these disclosures and your tabular presentation presented
on page F-22 that for US GAAP purposes, specifically FIN14, there was no amount within your
range of loss that was a better estimate than any other amount such that you accrued the
lower end of the range of loss. Please revise your disclosures to better clarify your
accounting. In addition, please further clarify that for US GAAP purposes, specifically
FIN39, you have not net the $393 million insurance recoveries against your asbestos-related
liabilities and that pursuant to paragraph 140 of SOP 96-1, you have only recorded probable
insurance recoveries. Please revise your disclosures throughout the filing to provide these
clarifying disclosures.

    At March 31, 2006, the Company determined that it was appropriate to record a provision for
what had become a probable and estimable liability. The amount that was recorded was based on the terms of
the proposed FFA, which included an actuarial estimate prepared by KPMG Actuaries (“KPMGA”)
as of March 31, 2006 of the projected future cash outflows, undiscounted and uninflated, and
the anticipated tax deduction arising from Australian legislation which came into force on April 6, 2006.

    Following the finalization of the asbestos funding arrangements in February 2007, the 20-F
includes additional disclosure intended to help the reader assess the Company’s asbestos
liability. In arriving at the provision value, the Company again relied on an estimate
provided by KPMGA. Based on KPMGA’s assumptions, KPMGA arrived at a range of possible total
cash flows, although as part of their work they proposed a central estimate which is
intended to reflect an expected outcome. The Company views the central estimate as the
basis for recording the asbestos liability in the Company’s financial statements, which,
under U.S. GAAP, it considers the best estimate under SFAS 5. The Company will add
clarifying disclosures in future filings.

    Furthermore, as stated on page F-14, the Company based the value of the liability on
undiscounted and uninflated cash flows as it believes that it is inappropriate to discount
or inflate future cash flows when the timing and amounts of such cash flows is not fixed or
readily determinable.

    In an effort to provide additional information and to indicate the impact of inflation on
the future cash flows, the Company refers to the undiscounted (but inflated) central
estimate of A$2.8 billion on pages F-21 and F-23. It is the Company’s view that when read in
conjunction with the accounting policy on page F-14, the reader is better able to determine
how and why the Company arrived at the level of liability recorded. In future filings the
Company will use the words “but inflated” where appropriate.

    The table on page F-22 is intended to show how the Company’s liability under the funding
arrangements is presented on the Company’s balance sheet. The Company confirms that in
accordance with FIN 39, it has not netted the $393 million insurance recoveries against its
asbestos-related liabilities. The Company notes that this table includes amounts for the
asbestos liability, the receivables for insurance and all other components of the liability

Securities and Exchange Commission

Page 5

    which are recorded on a gross basis as separate items which agree to the captions on the
balance sheet.

    The Company confirms that only probable insurance recoveries have been recorded in
accordance with paragraph 140 of SOP 96-1. The Company has included such clarifying
disclosure in its recent financial statements and it is the Company’s intention to continue
including such disclosure in its future filings. See the Company’s financial statements for
the quarter ended June 30, 2007, furnished to the SEC on August 17, 2007 on Form 6-K.

    5.

    We note your tabular presentation of the adjustments to the net Amended FFA liability
presented on page F-21. For readers of your US GAAP financial statements, please also provide
a rollforward of your gross asbestos liability for each balance sheet date presented.
Separately disclose changes in your estimated future asbestos-related liabilities from your
from your funding payments. In this regard, we note that you recognized $405.5 million in
asbestos adjustments during the year ended March 31, 2007. Your disclosures on page 54
indicate that $335.0 million of this adjustment relates to the tax effect related to the
implementation of the Final Funding Agreement. Please clarify supplementally and revise your
disclosures to clarify why taxes impact your FFA liability and the related provision you have
recognized during the period.

    No rollforward of the asbestos-related assets and liabilities was included in the 20-F
because the balance sheet contained in the 20-F was the first balance sheet to include the
liability on a gross basis. However, the Company has included this presentation in its
recent financial statements, and it is the Company’s intention to continue including this
presentation, in its future filings. See the Company’s financial statements for the quarter
ended June 30, 2007, furnished to the SEC on August 17, 2007 on Form 6-K.

    At March 31, 2006, the Company recorded an asbestos provision based on the estimated
economic reality of the proposed FFA. The amount of the asbestos provision of $715.6
million was based on the terms of the proposed FFA, which included an actuarial estimate
prepared by KPMGA as of March 31, 2006 of the projected future cash outflows, undiscounted
and uninflated, and the anticipated tax deduction arising from Australian legislation which
came into force on April 6, 2006. The amount represented the net economic impact that the
Company was prepared to assume as a result of its voluntary funding of the asbestos
liability which was under negotiation with various parties.

    Upon signing of the FFA in 2007, in accordance with Financial Accounting Standards Board
Interpretation No. 46R, “Consolidation of Variable Interest Entities”, the Company
consolidated the AICF with the Company resulting in a gross-up of the asbestos liability and
certain other items including the related Australian income tax benefit. Among other items,
the Company recorded a deferred tax asset for the anticipated tax benefit related to
recorded charges and a corresponding increase in the asbestos liability. As stated on page
F-14, the Company’s Performing Subsidiary, James Hardie 117 Pty Ltd, will be able to claim a
taxable deduction for contributions to the asbestos fund. In the Company’s 2007 statement of
operations, the Company classified the expense related to the increase of the asbestos
liability as asbestos adjustments and the Company classified the benefit related to the
recording of the related deferred tax asset as income tax benefit (expense).

Securities and Exchange Commission

Page 6

Australian Securities and Investments Commission (`ASIC’) Proceedings and Investigation — Page
F-25

    6.

    You indicate that there remains considerable uncertainty surrounding the likely outcome of
the ASIC proceedings in the long term and there is a possibility that the related costs could
be material. However, at this stage, it is not possible to determine the amount of such
liability. Therefore, both the probable and estimable requirements under SFAS 5 for recording
a liability have not been met. While the probable and estimable requirements for recording a
liability may not have been met, you indicate that there is a possibility that the related
costs could be material. Please tell us and disclose