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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

 F: +353 (0) 1 497 1128

 April 11, 2013

 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

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

Filed July 2, 2012

Form 6-K

Filed November 16, 2012

Form 6-K

Filed March 1, 2013

File No. 1-15240

 Dear Mr. Decker:

 Transmitted herewith is the response of James Hardie Industries plc (the “Company”) to the Staff’s supplemental
comments, by letter dated March 14, 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”), Form 6-K furnished on
November 16, 2012 and Form 6-K furnished on February 26, 2013. 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 respective Form 6-K. Courtesy copies of this letter
are being delivered to Ernest Greene and Nudrat Salik.

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

 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.

 We
acknowledge your comment and hereby provide the additional disclosure or other revisions 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.
We note your response to comment two from our letter dated January 9, 2013. In your proposed disclosure, you indicate that the U.S. GAAP effective tax rate is
not meaningful as it was favorably impacted by RCI’s successful appeal of the ATO’s disputed 1999 amended tax assessment. Please ensure that you discuss your U.S. GAAP effective tax rate in the same manner as your comparable non-GAAP
financial measure and that your corresponding disclosures do not place more prominence on the non-GAAP financial measures. Refer to Item 10(e) of Regulation S-K.

We note the Staff’s comment regarding the discussion of the U.S. GAAP effective tax rate as set forth in our proposed disclosure in
our response letter to the Staff dated February 25, 2013. As discussed with the Staff in a telephone exchange on March 25, 2013, the Company will also amend its disclosures in future filings to discuss changes in our U.S. GAAP effective
tax rate in a manner that does not place more prominence on the corresponding non-GAAP financial measure.

 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 effective
tax benefit rate was 299.9% in fiscal year 2012, compared to an effective income tax expense rate of 459.2% in fiscal year 2011. The effective tax benefit rate in fiscal year 2012 was materially 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, compared to an income tax expense of US$345.2 million in fiscal year 2011, as further discussed below. The Company’s effective tax benefit
rate in fiscal year 2012 was also impacted by unfavourable asbestos adjustments of

 Mr. Rufus Decker

 Securities and Exchange Commission

  Page
 3

US$15.8 million, compared to US$85.8 million in the prior year, and an asset impairment charge of US$14.3 million, compared to nil in the prior year.

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 income in 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.

 Form 6-K filed November 16, 2012

Exhibit 99.2

3.
We note your response to comment five from our letter dated January 9, 2013. With regard to the quantitative reconciliation of non-GAAP financial measures that
are forward-looking, Regulation G requires a schedule or other presentation detailing the differences between the forward-looking non-GAAP financial measure and the appropriate forward-looking GAAP financial measure. If the GAAP financial measure is
not accessible on a forward-looking basis, you should disclose that fact and provide reconciling information that is available without an unreasonable effort. Furthermore, you should identify information that is unavailable and disclose its probable
significance. Please revise your disclosures accordingly. Refer to SEC Release No. 33-8176.

 We note the
Staff’s comment seeking a quantitative reconciliation of our non-GAAP forward-looking financial measure to the appropriate forward-looking GAAP financial measure.

 As discussed with the Staff in a telephone exchange on March 25, 2013, we are unable to determine, without unreasonable effort, the effect that asbestos adjustments will have on the most directly
comparable forward-looking U.S. GAAP financial measure, being forecasted net income (net operating profit). Since asbestos-related assets and liabilities are denominated in Australian dollars, asbestos adjustments, together with their tax effect, as
applicable, reflect the impact on our earnings arising from movements in foreign currency exchange rates as well as changes in actuarial estimates.

 Either or both of these uncertainties can materially impact our earnings. For example, within the preceding five fiscal years, the Company’s asbestos adjustments have ranged from favourable asbestos
adjustments of US$17.4 million in fiscal year 2009 to unfavourable asbestos adjustments of US$224.2 million in fiscal year 2010. In addition, while our non-GAAP forward-looking financial measure assumes an average exchange rate, we are unable to
reasonably determine, on a forward-looking basis, the extent to which our full year earnings will be impacted by movements in foreign currency exchange rates.

 Mr. Rufus Decker

 Securities and Exchange Commission

  Page
 4

 As
a result, we are unable to forecast or adequately reconcile, without unreasonable effort, the most directly comparable U.S. GAAP forward-looking financial measure.

 Accordingly, in future filings, the Company will indicate that it is unable to provide, without unreasonable effort, the most directly comparable U.S. GAAP forward-looking financial measure, due to
material uncertainties regarding the impact to earnings in future periods of asbestos adjustments, which include foreign currency exchange rates and changes in actuarial adjustments. 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 dated November 16, 2012:

 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 most directly comparable U.S. GAAP forward-looking financial measure due to material uncertainties regarding the extent to which the company’s earnings will be impacted by asbestos adjustments, which include fluctuations
in foreign currency exchange rates and changes in actuarial adjustments, together with their related tax effect, as applicable. These uncertainties may have a material impact on the company’s forecast full year earnings.

Exhibit 99.3

4.
We note your response to comment six from our letter dated January 9, 2013. Given that the description operating profit before income taxes could be viewed to
be confusingly similar to your operating income line item presented in your U.S. GAAP financial statements and Rule 5-03 of Regulation S-X would imply that items such as interest expense and interest income would not generally be included in the
determination of operating income or profit, please help us better understand how you determined your current presentation of operating profit before income taxes is appropriate. Please also tell us what consideration you gave to changing the
description of the line item currently described as EBIT to operating income to be consistent with the financial statements provided in 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.

 We note the Staff’s comment regarding line item descriptions used in our Form
6-K. We supplementally advise the Staff that as a foreign incorporated entity listed on the Australian Securities Exchange (“ASX”), we are subject to ASX listing rules and Australian law regarding continuous and periodic disclosure. These
disclosure requirements require us to lodge with the ASX, on a regular basis, a review of our results of operations. Accordingly, to meet our reporting requirements to the ASX and as required by Australian law, we lodge with the ASX a
“Management’s Analysis of Results”, together with our financial statements,

 Mr. Rufus Decker

 Securities and Exchange Commission

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and furnish this information in a Form 6-K under our continuous disclosure requirements in the United States.

 As the majority of our security holders are resident in Australia, and in light of our reporting requirements under ASX listing rules and Australian law, we use line item descriptions applicable to our
reporting requirements in Australia in the review of our results of operations.

 To align the review of our results of
operations, as contained within Management’s Analysis of Results, with our financial statements, we have provided a “Definitions” section which cross-references the Australian line item descriptions to the corresponding U.S. GAAP
descriptions in our financial statements.

 As discussed with the Staff, we will provide additional clarification on the
terminology differences in future Form 6-K reports (beginning with the Company’s Form 6-K, which we expect to furnish on May 22, 2013), and amend the “Definitions” section as follows in Exhibits 99.2 and 99.3:

Financial Measures

 This document contains financial statement line item descriptions that are considered to be non-U.S. GAAP, but are consistent with those used by Australian companies. Because the company prepares its
consolidated financial statements under U.S. GAAP, the following table cross-references each non-U.S. GAAP line item description, as used in Management’s Analysis of Results and Media Release, to the equivalent U.S. GAAP financial statement
line item description used in the company’s consolidated financial statements:

 Management’s Analysis of Results

 and Media Release

 Consolidated Statements of Operations

 (US GAAP)

Net sales

Net sales

Cost of goods sold

Cost of goods sold

 Gross profit

 Gross profit

Selling, general and administrative expenses

Selling, general and administrative expenses

Research and development expenses

Research and development expenses

Asbestos adjustments

Asbestos adjustments

 EBIT *

 Operating income (loss)

Net interest (expense) income *

Sum of interest expense and interest income

Other income (expense)

Other income (expense)

 Operating profit (loss) before income taxes *

 Income (loss) before income taxes

Income tax expense

Income tax expense

 Net operating profit (loss) *

 Net income (loss)

*
Represents non-US GAAP descriptions used by Australian companies.

 Mr. Rufus Decker

 Securities and Exchange Commission

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5.
We note your response to comment seven from our letter dated January 9, 2013. We continue to have difficulty understanding how you determined it was appropriate
to present full non-GAAP financial statements for purposes of reconciling non-GAAP measures to the most directly comparable U.S. GAAP measures. Please revise your presentation to provide relevant information to investors without providing full
non-GAAP financial statements.

 Alternatively, you may consider including summary financial information
rather than 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 for purposes of reconciling non-GAAP measures to the most directly comparable U.S. GAAP measures. As discussed with the Staff, we will remove the full non-GAAP financial statements in future Form
6-K reports. Instead, we will present a summary of selected financial information in order to disclose the relevant information to users of our financial statements regarding the impact of asbestos on our consolidated financial position and results
of operations. The following is an example of the anticipated revision to our disclosure in Exhibit 99.3:

 Supplemental
Financial Information

 As set forth in Note 7 of the 30 September 2012 Condensed Consolidated Financial Statements,
the net AFFA liability, while recurring, is based on periodic actuarial determinations, claims experience and currency fluctuations. The company’s management measures its financial position, operating performance and year-over-year changes in
operating results with and without the effect of the net AFFA liability. Accordingly, management believes that the following non-GAAP information is useful to it and investors in evaluating the company’s financial position and ongoing operating
financial performance. The following non-GAAP table should be read in conjunction with JHI plc’s consolidated financial statements and related notes contained in the company’s 30 September 2012 Condensed Consolidated Financial
Statements.

 Mr. Rufus Decker

 Securities and Exchange Commission

  Page
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Supplementary Financial Information

 30 September 2012

 (Unaudited)

 (Millions of US dollars)

Total Fibre
Cement –
Excluding
Asbestos
Compensation

Asbestos
Compensation

As
Reported
(US GAAP)

 Restricted cash and cash equivalents – Asbestos

$
 —

$
63.2

$
63.2

 Restricted short-term investments – Asbestos

—

116.8

116.8

 Insurance receivable – Asbestos¹

—

209.0

209.0

 Workers compensation asset – Asbestos¹

—

84.4

84.4

 Deferred income taxes – Asbestos¹

—

431.6

431.6

 Asbestos liabi