January 16, 2026

Jason Crawford
Chief Financial Officer
AZZ INC
One Museum Place, Suite 500
3100 West 7th Street
Fort Worth, TX 76107

       Re: AZZ INC
           Form 10-K for the Fiscal Year Ended February 28, 2025
           Form 10-Q for the Fiscal Quarter Ended November 30, 2025
           File No. 001-12777
Dear Jason Crawford:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments.

       Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this letter, we may have additional
comments.

Form 10-Q for the Fiscal Quarter Ended November 30, 2025
Financial Statements for the Nine Months Ended November 30, 2025
Condensed Consolidated Statements of Cash Flows, page 6

1.     We note the $273.2 million distribution on investment in AVAIL joint
venture
       classified within operating activities. We further note from your
disclosures in Note 8
       that at the time of this distribution, the amount of the distribution
exceeded your
       investment in the AVAIL JV of $107.4 million, resulting in the reduction
of your
       investment in the AVAIL JV to zero and recognition of the excess amount
of
       distribution as a gain. With a view to clarifying how you determined
that none of this
       distribution amount was a return of your investment in the AVAIL JV that
would be
       classified as an investing activity as contemplated by ASC
230-10-45-12(b), please
       revise your upcoming February 28, 2026 Form 10-K to provide an
accounting policy
       clarifying whether you have elected to follow the cumulative earnings
approach or the
       nature of the distribution approach when determining the classification
of distributions
 January 16, 2026
Page 2

       received from equity method investees, and provide similar information
to us in your
       response. Refer to ASC 230-10-45-21D.
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Results of Operations, page 31

2.     We note that when analyzing the change in revenue for each of your
segments, you
       indicate the change resulted from a change in volume, partially offset
by a change in
       selling price. While you have provided management's perspective on the
underlying
       factors contributing to the change in selling price, you have not
provided similar
       insight from management into the underlying factors contributing to the
change in
       volume. We further note that management appears to have insight into
these
       underlying factors based on the disaggregation of revenue by end market
provided in
       Note 5 and the discussion in your third quarter earnings call of strong
demand from
       infrastructure projects. Please revise your analysis of changes in
revenue in your
       upcoming February 28, 2026 Form 10-K to provide management's insight
into the
       underlying factors contributing to changes in volume, in addition to
those contributing
       to changes in selling price. Refer to Item 303 of Regulation S-K and SEC
Release No.
       33-8350.
        In closing, we remind you that the company and its management are
responsible for
the accuracy and adequacy of their disclosures, notwithstanding any review,
comments,
action or absence of action by the staff.

       Please contact SiSi Cheng at 202-551-5004 or Jennifer Thompson at
202-551-3737
with any questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of
Manufacturing