March 29, 2005

Via U.S. Mail

Dr. Jurgen Hambrecht
Chairman of the Board of Executive Directors
BASF Aktiengesellschaft
Carl Bosch Strasse 38
Ludwigshafen, Germany 67056

RE:		BASF Aktiengesellschaft
      Form 20-F for the fiscal year ended December 31, 2004
		File No. 1-15909

Dear Mr. Hambrecht:

      We have limited our review of your Form 20-F to disclosures
relating to your contacts with countries that have been identified
as
state sponsors of terrorism, and will make no further review of
the
Form 20-F.  Our review with respect to this issue does not
preclude
further review by the Assistant Director group with respect to
other
issues.  At this juncture, we are asking you to provide us with
supplemental information, so that we may better understand your
disclosure.  Please be as detailed as necessary in your response.
After reviewing this information, we may or may not raise
additional
comments.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your
filings.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.


General -

We note the disclosure in the 20-F regarding the Company`s
operations
in Libya, including the statement on page 45 that in 2004,
"approximately 69% of the Oil & Gas segment`s oil reserves and
production activities were in Libya, where the segment operates
several onshore oil fields and produces associated natural gas for
local consumption."  We also note that in Exhibit 4.2 to its 20-F,
the Company states it has a wholly owned subsidiary named BASF
Iran
AG that operates from Tehran, Iran.

In light of the fact that Libya and Iran have been identified by
the
U.S. State Department as state sponsors of terrorism, and Iran is
subject to economic sanctions administered by the U.S. Treasury
Department`s Office of Foreign Assets Control, and Libya was
subject
to economic sanctions until September 21, 2004, please summarize
for
us the Company`s operations in each of these countries, and
describe
for us the materiality to the Company of its operations in each
country and your view as to whether those operations, individually
or
in the aggregate, constitute a material investment risk for your
security holders.  In preparing your response please consider that
evaluations of materiality should not be based solely on
quantitative
factors, but should include consideration of all factors,
including
the potential impact of corporate activities upon a company`s
reputation and share value, that a reasonable investor would deem
important in making an investment decision.


Closing

      Please understand that we may have additional comments after
we
review your response to our comment.  Please contact Jack
Guggenheim
at (202) 942-7896 if you have any questions about the comment or
our
review.  You may also contact me at (202) 942-7817.



								Sincerely,



								Cecilia D. Blye, Chief
								Office of Global Security
Risk



cc: 	Pamela Long
		Assistant Director
		Division of Corporation Finance