Mail Stop 6010
Via Facsimile and U.S. Mail


September 15, 2005

Mr. Jorg Spiekerkotter
Chief Financial Officer
Schering Aktiengesellschaft
Muellerstrasse 178
13353 Berlin
Federal Republic of Germany

      Re:	Schering Aktiengesellschaft
		Form 20-F for Fiscal Year Ended December 31, 2004
	            File No. 001-16143

Dear Mr. Spiekerkotter:

      We have limited our review of your filing to the issue we
have
addressed in our comment.  In our comment, we ask you to provide
us
with information so we may better understand your disclosure.
After
reviewing this information, we may 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 filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.


Item 5. Operating and Financial Review and Prospects
1. We believe that your disclosure related to estimates that
reduce
gross revenue such as product returns, rebates and discounts could
be
improved.  Please provide us the following information in
disclosure-
type format:

a. The nature and amount of each accrual at the balance sheet date
and the effect that could result from using other reasonably
likely
assumptions than what you used to arrive at each accrual such as a
range of reasonably likely amounts or other type of sensitivity
analysis.
b. The factors that you consider in estimating each accrual such
as
historical return of products, levels of inventory in the
distribution channel, estimated remaining shelf life, price
changes
from competitors and introductions of generics and/or new
products.
c. To the extent that information you consider in b) is
quantifiable,
disclose both quantitative and qualitative information and discuss
to
what extent information is from external sources, such as end-
customer prescription demand, third-party market research data
comparing wholesaler inventory levels to end-customer demand. For
example, in discussing your estimate of product that may be
returned,
explain, preferably by product and in tabular format, the total
amount of product in sales dollars that could potentially be
returned
as of the balance sheet date and disaggregated by expiration
period.
d. If applicable, any shipments made as a result of incentives
and/or
in excess of your customer`s ordinary course of business inventory
level.  Disclose your revenue recognition policy for such
shipments.
e. A roll forward of the accrual for each estimate for each period
presented showing the following:
* Beginning balance,
* Current provision related to sales made in current period,
* Current provision related to sales made in prior periods,
* Actual returns or credits in current period related to sales
made
in current period,
* Actual returns or credits in current period related to sales
made
in prior periods, and
* Ending balance.

f. Regarding your discussion of results of operations for the
period
to period net sales comparisons, the amount of and reason for
fluctuations for each type of reduction of gross sales, i.e.
product
returns, rebates and discounts, including the effect that changes
in
your estimates of these items had on your net sales and
operations.


*    *    *    *

      Please respond to the comment within 10 business days or
tell
us when you will provide us with a response.  Please furnish a
letter
that keys your response to our comment and provides requested
information.  Detailed letters greatly facilitate our review.
Please
file your letter on EDGAR under the form type label CORRESP.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings to be certain that the
filing includes all information required under the Securities and
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision.  Since the
company and its management are in possession of all facts relating
to
a company`s disclosure, they are responsible for the accuracy and
adequacy of the disclosures they have made.

	In connection with responding to our comment, please provide,
in
your letter, a statement from the company acknowledging that

* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;
* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and
* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

	In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

      You may contact Todd Sherman, Staff Accountant, at 202-551-
3665
or Don Abbott, Senior Accountant, at 202-551-3608 if you have
questions regarding the comment.  In this regard, do not hesitate
to
contact me, at (202) 551-3679.

							Sincerely,



							Jim B. Rosenberg
						Senior Assistant Chief Accountant
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Jorg Spiekerkotter
Schering Aktiengesellschaft
September 15, 2005
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