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CORRESP

                       James Hardie Industries
plc

                       Europa House 2nd Floor,

                       Harcourt Centre

                       Harcourt Street, Dublin
2, Ireland

                       T: +353 (0) 1 411 6924

February 25, 2013

                       F: +353 (0) 1 497 1128

 VIA EDGAR AND OVERNIGHT DELIVERY

 Securities and Exchange Commission

 Division of Corporation Finance

100 F Street, N.E., Stop 4631

 Washington D.C.
20549

 Attention: Mr. Rufus Decker

Re:
James Hardie Industries plc

File No. 1-15240

Form 20-F for the fiscal year ended March 31, 2012

Filed July 2, 2012

Form 6-K

Filed November 16, 2012

 Dear Mr Decker:

 Transmitted herewith is the response of James Hardie Industries plc (the “Company”) to the Staff’s comment
letter dated January 9, 2013 (the “Comment Letter”), regarding the Company’s Annual Report on Form 20-F for the fiscal year ended March 31, 2012 (the “Form 20-F”) and Form 6-K furnished to the Staff on
November 16, 2012 (the “Form 6-K”). For ease of reference, the Company has reproduced below the comments set forth in the Comment Letter, as numbered, in bold type before each of its responses. Unless otherwise noted, page numbers
included herein are page references to the Form 20-F or Form 6-K, and capitalized terms used but not defined herein have the meanings ascribed to such terms in the Form 20-F or Form 6-K. Courtesy copies of this letter are being delivered to Ernest
Greene and Nudrat Salik.

 Form 20-F for the Year Ended March 31, 2012

 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.
These revisions should be included in your future filings, including your interim filings, if applicable.

James Hardie Industries plc is a limited liability company incorporated in Ireland with its registered office at

Europa House, Harcourt Centre, Harcourt Street, Dublin 2, Ireland.

 Directors: Michael Hammes (Chairman), Brian Anderson (USA), David Dilger, David Harrison (USA),

 Alison Littley (United Kingdom), Donald McGauchie (Australia), James Osborne, Rudy van deer Meer (Netherlands),

 Chief Executive Officer: Louis Gries

 Company number: 485719

 Mr. Rufus Decker

 Securities and Exchange Commission

  Page
 2

 We acknowledge your comment and will provide additional disclosure or other revisions
supplementally as requested. We will include the additional disclosure or other revisions as noted below in future filings, including interim financial reports that are furnished to the Staff on our Form 6-K, as applicable.

Management’s Discussion and Analysis, page 83

 Year Ended 31 March 2012 Compared to Year Ended 31 March 2011, page 89

 Income
Tax Benefit (Expense), page 93

2.
When you present or discuss changes between periods in a non-GAAP financial measure as an amount or percentage, such as but not limited to your discussion of the
effective tax rate of earnings excluding asbestos, asset impairments, and tax adjustments, please ensure that you do so in the same manner with the comparable GAAP financial measure. Refer to Item 10(e) of the Regulation S-K.

 We note the Staff’s comment regarding the use of non-GAAP financial measures, including but not limited
to the effective tax rate of earnings excluding asbestos, asset impairments and tax adjustments. The Company will expand its disclosures in future filings to include a discussion of changes between periods in the comparable GAAP financial measure in
the same manner that it discusses changes in the non-GAAP financial measure. We respectfully advise the Staff that the Company has provided a reconciliation of non-GAAP financial measures, including the effective tax rate of earnings excluding
asbestos, asset impairments and tax adjustments, beginning on page 100 of the Form 20-F.

 The following is an example of the
anticipated revision to our future disclosure based on page 93 of our Form 20-F:

 The Company’s U.S. GAAP effective tax
rate is not meaningful, as it was favourably impacted by RCI’s successful appeal of the ATO’s disputed 1999 amended tax assessment, resulting in an income tax benefit of US$485.2 million in fiscal year 2012, compared to an income tax
expense of US$345.2 million in fiscal year 2011, as further discussed below. The Company’s effective tax rate was also impacted by asbestos adjustments and an asset impairment charge incurred in fiscal year 2012.

The Company’s effective tax rate excluding asbestos, asset impairments and tax adjustments was 22.9% in fiscal year 2012, compared to
31.1% in fiscal year 2011, due to a higher proportion of taxable jurisdictions with lower statutory income tax rates. The Company’s geographic mix of earnings and expenses is also affected by fluctuations in foreign currency exchange rates of
the US dollar to relevant local jurisdiction currencies.

 Mr. Rufus Decker

 Securities and Exchange Commission

  Page
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 Liquidity and Capital Resources, 103

 General

3.
Since your foreign operations appear to be significant, please disclose the following:

•

 The amount of cash and short term investments held by foreign subsidiaries as compared to your total amount of cash and short-term
investments as of year end;

•

 You would be required to accrue and pay taxes to repatriate these funds and you do not intend to repatriate them, if true;

•

 Quantify the amount of cash and short-term investments held by foreign subsidiaries where the funds are not readily convertible into other
foreign currencies, including U.S. dollars. Please also explain the implications of any such restrictions upon your liquidity.

 Refer to Item 303(a)(1) of Regulation S-K, SEC Release 33-8350 Section IV and Financial Reporting Codification 501.06.a.

We note the Staff’s comment regarding cash and short term investments held by our foreign subsidiaries. We respectfully advise the
Staff that, in accordance with SEC Release 33-8350 Section IV, we have limited our discussion of liquidity and capital resources to those matters that we believe are material to critically assess our ability to generate cash and to meet existing and
known or reasonably likely future cash requirements. On that basis, we believe our current disclosures regarding liquidity and capital resources are sufficient based on the following:

•

 We are a public limited company domiciled in, and resident for tax purposes in, Ireland. The Company has centralized its treasury and cash management
function in Ireland. Accordingly, we supplementally advise the Staff that the amount of cash held by non-Irish subsidiaries at March 31, 2012 is immaterial.

•

 The Company’s significant cash balance at March 31, 2012 arose due to a tax refund of US$396.3 million received by a non-Irish subsidiary,
which was held by our centralized treasury and cash management function in Ireland at March 31, 2012. We respectfully advise the Staff that, on page 106 of our Form 20-F, the Company disclosed that it was not required to recognize deferred
taxes in association with undistributed profits of this non-Irish subsidiary.

•

 Since we do not have any material cash or short-term deposits held by non-Irish subsidiaries, we do not have funds that are not readily convertible
into other foreign currencies, and therefore have no such material restrictions on our liquidity that would merit additional disclosure regarding such restrictions.

 Mr. Rufus Decker

 Securities and Exchange Commission

  Page
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 Financial Statements

 Notes to the Financial Statements

 Note 9. Long Term Debt, page 129

4.
You disclosed that you were in compliance with all debt covenants at March 31, 2012. Please disclose the specific terms of these debt covenants with any
required ratios/amounts. Please disclose the actual ratios/amounts as of each reporting date for any material debt covenants for which it is reasonably likely that you will not be able to meet. Please also consider showing the specific computations
used to arrive at the actual ratios/amounts with corresponding reconciliations to US GAAP amounts. See Sections I.D and IV.C of the SEC Interpretive Release No. 33-8350 and Compliance and Disclosures Interpretation 102.09 which is
available on our website at http://www.sec.gov/divisions/corpfin/guidance/nongaapinterp.htm.

 We note
the Staff’s comment seeking additional disclosure of the specific terms, ratios/amounts and specific computations related to the Company’s debt covenants. We respectfully advise the Staff that the Company held a significant cash balance at
March 31, 2012 and, as reported on page 130 of our Form 20-F, the Company had no outstanding debt and disclosed the nature of the debt covenants to which we are subject. We believe our current disclosure regarding our debt covenants is
sufficient based on the following:

•

 We expect to remain well within our debt covenants, and we do not believe that we are reasonably likely to breach, or be at risk of breaching, any of
our debt covenants in the foreseeable future.

•

 We do not believe our debt covenants are reasonably likely to materially limit our ability to undertake future financings to meet our future capital
requirements, including the payment of dividends to shareholders.

 However, we will seek to enhance our
disclosure in future filings, in accordance with the Staff’s comment, in the event we believe our debt covenants are reasonably likely to have a material adverse effect on our liquidity and capital resources, as noted above.

Form 6-K Filed November 16, 2012

Exhibit 99.2

5.
You present non-GAAP forward looking information, including net operating profit excluding asbestos and earnings excluding asbestos, ASIC expenses, and tax
adjustments. Please present the most directly comparable GAAP financial measures and provide a quantitative reconciliation of the differences between the non-GAAP and GAAP financial measures, to the extent available without unreasonable efforts.
Refer to Item 100(a) of Regulation G.

 Mr. Rufus Decker

 Securities and Exchange Commission

  Page
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 We note the Staff’s comment regarding the use of non-GAAP forward looking
information in our earnings guidance, including the Company’s fiscal year 2013 forecasted net operating profit excluding asbestos, ASIC expenses and tax adjustments.

 We supplementally advise the Staff that the most directly comparable financial measure calculated and presented in accordance with U.S. GAAP is net income (net operating profit).

The U.S. GAAP financial measure of net operating profit includes adjustments for certain asbestos-related assets and liabilities that are
actuarially assessed on an annual basis. As disclosed on page 124 of our Form 20-F, adjustments in the asbestos liability and related insurance receivable due to changes in the actuarial estimate of projected future cash flows, changes in the
estimate of future operating costs of AICF and changes in the assessment of recoverability under existing insurance policies held by AICF are reflected in the consolidated statements of operations during the period in which they occur. We
respectfully advise the Staff that we are unable to determine, without unreasonable effort, the impact of changes in actuarial estimates on our asbestos-related assets and liabilities, which could have a material impact on our forecasted earnings.

 Because we are unable to forecast, without unreasonable effort, the impact of movements in actuarial estimates on our
asbestos-related assets and liabilities in future periods, we are unable to present the most directly comparable financial measure calculated and presented in accordance with U.S. GAAP.

In future filings, the Company will modify its disclosure indicating that it is unable to provide, without unreasonable effort, a
quantitative reconciliation of the differences between the non-GAAP and comparable GAAP forward-looking financial measure. The following is an example of the anticipated revision to our future disclosure based on page 5 of Exhibit 99.2 (Media
Release) of our Form 6-K:

 Full Year Earnings Guidance

Management expects full year earnings excluding asbestos, ASIC expenses and tax adjustments to be between US$140 million and US$150
million assuming, among other things, housing industry conditions in the United States continue to improve, the accounting provision for New Zealand product liability expenses remains adequate and that an average exchange rate of approximately
US$1.04/A$1.00 applies for the balance of the year ending 31 March 2013. The Company is unable to forecast the comparable U.S. GAAP financial measure due to uncertainty regarding the impact of actuarial estimates on asbestos-related assets and
liabilities in future periods.

 Mr. Rufus Decker

 Securities and Exchange Commission

  Page
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 Exhibit 99.3

6.
You present operating profit before income taxes and net operating profit. You include net interest (expense) income and other income (expense) in your determination
of operating profit before income taxes. Your Form 20-F for the year ended March 31, 2012 as well as the financial statements provided in Exhibit 99.5 of this Form 6-K present an operating income line item which excludes interest expense,
interest income, and other income (expense). In this regard, please tell us how you determined it was appropriate to include net interest (expense) income and other income (expense) in your determination of operating profit before income taxes in
the financial information provided in Exhibit 99.2. Please also tell us what consideration you gave to changing the description to the line item currently described as EBIT to operating income to be consistent with the financial statements provided
in Exhibit 99.5 of this Form 6-K.

 We note the Staff’s comment regarding the presentation of different
financial statement measurements used in the Condensed Consolidated Financial Statements and Management’s Analysis of Results, included as exhibits 99.5 and 99.3, respectively, to our Form 6-K.

The Company respectively advises the Staff that, included in our Form 6-K on pages 8 and 14 of Exhibit 99.2 and 99.3, respectively, is a
“Definitions” section which provides an appropriate cross reference to U.S. GAAP financial measures included in the Condensed Consolidated Financial Statements. In the “Definitions” section of the Form 6-K dated November 16,
2012, the Company noted that operating profit is equivalent to the U.S. GAAP measure of income.

 In future filings, the Company
will modify its “Definitions” section to clarify how operating profit before income taxes in Exhibit 99.3 cross references to the Condensed Consolidated Financial Statements included in Exhibit 99.5. The following is an example of the
anticipated revision to our future disclosure based on page 14 of Exhibit 99.3 (Management’s Analysis of Results) of our Form 6-K:

 Operating profit before income taxes – is equivalent to the US GAAP measure of income before income taxes.

7.
You present a full non-GAAP balance sheet, statement of operations, and statement of cash flows. Please revise your presentation to provide relevant information to
investors without providing full non-GAAP financial statements. For additional guidance, please refer to Compliance and Disclosures Interpretation 102.10 which is available on our website at
http://www.sec.gov/divisions/corpfin/guidance/nongaapinterp.htm.

 We note the Staff’s comment
regarding the presentation of full non-GAAP financial statements in Exhibit 99.3 of our Form 6-K. In this regard, we note that Compliance and Disclosures Interpretation 102.10 expresses the Staff’s view, without modifying Regulation G, that it
generally would be inappropriate to present a full non-GAAP income statement for purposes of reconciling non-GAAP measures to the most directly comparable U.S. GAAP measures.

 Mr. Rufus