Amrize Ltd

Grafenauweg 8

6300 Zug, Switzerland

May 7, 2025

Office of Manufacturing

Division of Corporation Finance

United States Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Claire Erlanger

Jay Ingram

Thomas Jones

Registration Statement on Form 10-12B

Filed February 28, 2025

File No. 001-42542

Ladies and Gentlemen:

Amrize Ltd (the “Company”) hereby provides responses to the comments received from the staff (the “Staff”) of the United States Securities and Exchange Commission (the “Commission”) set forth in the comment letter dated March 13, 2025 (the “Comment Letter”) with respect to the above-referenced Company’s Registration Statement on Form 10-12B (the “Registration Statement”). In response to the comments set forth in the Comment Letter, the Company has revised the Registration Statement and simultaneously is submitting Amendment No. 1 to the Registration Statement (“Amendment No. 1”) to the Commission.

The headings and paragraph numbers in this letter correspond to those contained in the Comment Letter and, to facilitate the Staff’s review, we have reproduced the text of the Staff’s comments in italics below. Unless otherwise stated, all references to page numbers and captions correspond to the page numbers and captions in the Registration Statement. Capitalized terms used but not defined herein have the meanings given to them in Amendment No. 1.

Response: The Company respectfully acknowledges the Staff’s comment and has included earnings per share and weighted average shares on a pro forma basis in the summary pro forma condensed combined statement of operations information on page 13 of Amendment No. 1.

Office of Manufacturing

Division of Corporation Finance

Securities and Exchange Commission

May 7, 2025

Page 2

Response: The Company respectfully acknowledges the Staff’s comment and has revised footnote (c) on page 84 and page 85 of Amendment No. 1 to present reconciliations in tabular format of the treasury adjustments described in footnotes (a) and (c) that aggregate to the total pro forma balance sheet adjustments to Cash and cash equivalents and Long-term debt. There is no pro forma adjustment impact to Cash and cash equivalents and Long-term debt from the treasury adjustments described in footnote (b) based on the Company entering certain transactions prior to the March 31, 2025 balance sheet date.

Response: The Company respectfully acknowledges the Staff’s comment and has revised the disclosure for footnote (b) on page 83 of Amendment No. 1 to state that the bridge loan and commercial paper program are not expected to be utilized upon the completion of the Spin-off. However, because the commercial paper program may be utilized depending on the Company’s cash position upon completion of the Spin-off, the disclosure has been expanded to include the potential impact of the issuance on Other current liabilities and Interest expense, net on the pro forma financial statements.

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Office of Manufacturing

Division of Corporation Finance

Securities and Exchange Commission

May 7, 2025

Page 3

We hope that the foregoing has been responsive to the Staff’s comments and look forward to resolving any outstanding issues as quickly as possible. Please direct any questions or comments regarding the foregoing to me at (212) 735-3743 or [email protected].

Samuel Cammer, Skadden, Arps, Slate, Meagher & Flom LLP

Jeremy Winter, Skadden, Arps, Slate, Meagher & Flom LLP

Urs Kägi, Bär & Karrer AG

Lukas Studer, Director, Amrize Ltd

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