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FOIA Confidential Treatment Requested by

Century
Aluminum Company Pursuant to 17 C.F.R. 200.83

(with respect to certain portions of this response)

Gerald C. Bialek, Chief Financial Officer

One South Wacker Drive

Suite 1000

Chicago, IL 60606

Tel: (312) 696-3101

January 17, 2025

BY ELECTRONIC TRANSMISSION

United States Securities and Exchange Commission

Office of Manufacturing

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

    Attention:
    Beverly Singleton

    Andrew Blume

    Re: Century Aluminum Company

    Form 10-K for the Fiscal Year Ended December 31,
    2023

    Form 10-Q for the Quarterly Period Ended September 30,
    2024

    File No. 001-34474

Dear Ms. Singleton and Mr. Blume:

Century Aluminum Company, a Delaware corporation (the “Company”),
hereby submits the following responses to the comments in the letter from the Office of Manufacturing in the Division of Corporation
Finance (the “Comment Letter”) dated December 18, 2024, with respect to the above-referenced filings. Set forth below
are the Staff’s comments followed by the Company’s responses to the comments. The numbering of the responses and the headings
set forth below correspond to the numbered comments and headings in the Comment Letter. The Staff’s comments are bolded.

Because of the commercially sensitive nature of information contained
herein, and pursuant to 17 C.F.R. § 200.83 (“Rule 83”), the Company requests confidential treatment from disclosure under
the Freedom of Information Act (“FOIA”), or otherwise, for portions of its responses to the Staff’s comments 4 (on the
pages marked [CENX-5], [CENX-6] and [CENX-7]) and 8 (on the page marked [CENX-13]). Specifically, the Company requests that the portions
of its response to the Staff’s comments 4 and 8 that have been redacted from the version of this letter filed via the Securities
and Exchange Commission’s (the “Commission”) EDGAR system and identified by the mark “[***]” be maintained
in confidence, not made part of any public record and not be disclosed to any person, including in response to any requests under FOIA,
or otherwise, as such responses contain confidential information. These responses are being provided to the Commission in their entirety
under separate cover along with the request for confidential treatment. The Company is also filing a redacted copy of this response letter
with the Office of Freedom of Information and Privacy Act Operations in connection with the confidential treatment request pursuant to
Rule 83. If any request is made for disclosure of these items, we would appreciate being notified promptly, so that we may provide further
support for our request for confidentiality.

    Confidential Treatment of Certain Portions

of the Response to Comments 4 and 8 Requested by

Century Aluminum Company Pursuant to 17 C.F.R. 200.83

[CENX – 1]

January 17, 2025

Page 2

Form 10-K for the Fiscal Year Ended December 31, 2023

Item 2. Properties, page 26

 1. We note that you do not include S-K 1300 mineral property disclosure
                                            for your 55% interest in Jamalco, including bauxite mining and alumina production in Jamaica.
                                            Please refer to Item 1301 of Regulation S-K regarding required mineral property disclosures
                                            and provide your materiality analysis associated with this property. Please note that the
                                            analysis should include all related activities from exploration through extraction to the
                                            first point of material external sale, including processing, transportation, and warehousing.

COMPANY RESPONSE:

We acknowledge the Staff’s comment and
respectfully advise the Staff that the Company has conducted a materiality analysis of its acquisition of General Alumina Holdings
Limited (“GAHL”), which includes its 55% interest in Jamalco, including all related activities from exploration through
extraction to the first point of material external sale (including processing, transportation, and warehousing), and determined that
Jamalco’s mineral operations may be material to the Company at and for the year ended December 31, 2024. Accordingly, the
Company intends to include the applicable S-K 1300 mineral property disclosures, including a Technical Report Summary, in its Annual
Report on Form 10-K for the year ended December 31, 2024.

We also respectfully advise the Staff that, with respect
to the year ended December 31, 2023, the Company had conducted a materiality analysis of its acquisition of GAHL, which includes
its 55% interest in Jamalco, including all related activities from exploration through extraction to the first point of material external
sale (including processing, transportation, and warehousing) at and for the fiscal year ended December 31, 2023. As a result of
this analysis, the Company determined that the Jamalco mineral extraction operations were not material to the Company for the fiscal
year ended December 31, 2023. This analysis was based on both quantitative and qualitative factors assessed in the context of our
overall business and financial condition in accordance with S-X 1301(C), including the following principal considerations:

 · the
                                            Company owned GAHL for only a portion of 2023;

 · the
                                            purchase price paid for the Company's interest in Jamalco was $1.00. In addition, the deemed
                                            purchase price paid for the Company’s interest in Jamalco included (i) approximately
                                            $8.3 million in respect of restricted cash acquired as of the completion date, and (ii) the
                                            assumption of approximately $7.9 million in liabilities (the “Deemed Purchase Price”).
                                            As the Company had not yet completed its purchase price accounting analysis as of December 31,
                                            2023, the Company viewed the Deemed Purchase Price to be the presumed fair value of the net
                                            assets acquired, and as such, determined that such Deemed Purchase Price represented approximately
                                            4.7% of the Company’s net assets as of December 31, 2023; and

    Confidential Treatment of Certain Portions

of the Response to Comments 4 and 8 Requested by

Century Aluminum Company Pursuant to 17 C.F.R. 200.83

[CENX – 2]

January 17, 2025

Page 3

 · the
                                            Jamaica-based long-lived assets reflected on the December 31, 2023, balance sheet (including
                                            Jamaica-based refining and processing assets) totaled approximately $272.2 million which
                                            is approximately 14.7% of the Company’s total assets as at December 31, 2023.
                                            The specific mineral reserve assets reflected on the December 31, 2023, balance sheet
                                            totaled approximately $57.6 million which is approximately 3.1% of the Company’s total
                                            assets as at December 31, 2023.

Management's Discussion and Analysis of Financial Condition
and Results of Operations Liquidity and Capital Resources

Year Ended December 31, 2023, Compared to Year Ended December 31,
2022, page 37

 2. Please provide a more informative analysis and discussion of changes
                                            in operating, investing and financing cash flows. In doing so, explain the underlying reasons
                                            and implications of material changes between periods to provide investors with an understanding
                                            of trends and variability in cash flows. Also provide an analysis of any known trends and
                                            uncertainties that will result in or that are reasonably likely to result in a material increase
                                            or decrease in your liquidity. Ensure your discussion and analysis is not merely a recitation
                                            of changes evident from the financial statements. Refer to Item 303(a) of Regulation
                                            S-K and Section IV.B of SEC Release No. 33-8350.

COMPANY RESPONSE:

The Company respectfully acknowledges the Staff’s comment. Beginning
with our Annual Report on Form 10-K for the year ended December 31, 2024, the Company will, in future filings, provide the
additional requested analysis and discussion of changes in operating, investing and financing cash flows including referencing Item 303(a) of
Regulation S-K and Section IV.B of SEC Release No. 33-8350.

With respect to our Annual Report for the Year
Ended December 31, 2023, the additional analysis and discussion would include the following for operating, investing and financing
cash flows:

The increase in cash provided by operations in 2023 compared
to 2022 was primarily due to decreased input prices such as coke and pitch, improved days sales outstanding, and higher due to affiliates
for cash received for future alumina shipments. The increase in operating cash flow was partially offset by an increase in the IRA Section 45X
receivable.

The decrease in net cash used in investing activities during
2023 was primarily attributable to $25.7 million in proceeds from the Mt. Holly Commerce Park Land sale and $11.5 million related to
the acquisition of Jamalco, net of cash acquired, partially offset by higher spending on capital projects during the twelve months ended
December 31, 2023. The change in capital project spend was driven by a $22.2 million increase at Grundartangi, mainly from the ongoing
casthouse project. This was partially offset by $12.7 million decrease at Mt. Holly, mainly due to the restart project being completed
in the second

    Confidential Treatment of Certain Portions

of the Response to Comments 4 and 8 Requested by

Century Aluminum Company Pursuant to 17 C.F.R. 200.83

[CENX – 3]

January 17, 2025

Page 4

quarter of 2022. We expect to complete capital spending on the Grundartangi casthouse project in 2024.

Net cash used in financing activities increased by $87.4
million to $(13.0) in 2023 from $74.4 in net cash provided by financing activities in 2022 primarily due to net repayments on our revolving
credit facilities in 2023 as compared to net borrowings in 2022. Additionally, the Company repaid outstanding borrowings from its Iceland
Term facility. This was partially offset by the sale of carbon credits and borrowings from the Vlissingen Facility Agreement.

Supplemental Guarantor Financial Information, page 38

 3. As required by Item 601(b)(22) of Regulation S-K, please revise future
                                            filings to include an Exhibit 22 listing each subsidiary guarantor, issuer or co-issuer.

COMPANY RESPONSE:

The Company respectfully acknowledges the Staff’s comment. Neither
the Company nor any of its subsidiaries has any registered debt securities that are issued and outstanding. However, the Company has
filed a shelf registration statement on Form S-3 (File No. 333-270681) (the “Form S-3”) registering, among
other securities, up to $350 million in aggregate principal amount of debt securities of the Company, which may be fully and unconditionally guaranteed by certain
of the Company’s subsidiaries previously identified in the Form S-3. In response to the Staff’s comment, the Registrant
confirms that it will include an Exhibit 22 as applicable (if and when we issue debt securities on the Form S-3), in future
filings identifying each subsidiary guarantor, issuer or co-issuer.

Notes to the Consolidated Financial Statements

2. Acquisition of Jamalco, page 60

 4. Citing authoritative GAAP guidance, where applicable, please address
                                            the following comments related to your May 2023 acquisition of Jamalco JV, an unincorporated
                                            joint venture:

 · Tell
                                            us how you determined you have a controlling financial interest in Jamalco and how your acquisition
                                            transaction is not subject to the scope exclusion of ASC 805-10-15-4(a). In doing so, explain
                                            if you consolidate Jamalco under a variable interest or voting interest model and clarify
                                            how you determined the Government of Jamaica, as the 45% interest holder, does not possess
                                            any powers or rights, such as substantive participating rights, that would preclude consolidation.

    Confidential Treatment of Certain Portions

of the Response to Comments 4 and 8 Requested by

Century Aluminum Company Pursuant to 17 C.F.R. 200.83

[CENX – 4]

January 17, 2025

Page 5

COMPANY RESPONSE:

The Company respectfully acknowledges and understands that the guidance
the Staff references in ASC 805-10-15-4(a) indicates that the formation of a joint venture is scoped out of the guidance in ASC
805 on Business Combinations and provides the following information regarding the Company’s assessment of the interest it obtained
in Jamalco.

The transaction on May 2, 2023, involved the Company’s acquisition
of 100% of the shares of General Alumina Holdings Limited (“GAHL”), which holds a 100% interest in General Alumina Jamaica
Limited (“GAJL”), which in turn, holds a 55% interest in, and is managing partner of, Jamalco. [***].

The Company further acknowledges the Staff’s request about the
Company’s conclusion that it should consolidate Jamalco, and whether such conclusion was reached through the variable interest
or voting interest model. The Company notes that we consolidate Jamalco under the variable interest entity model because Jamalco lacks
sufficient equity investment at risk in accordance with ASC 810-10-15-14. That is, based on its purpose and design, Jamalco is expected
to require additional subordinated financial support, such as those in the form of equity contributions or other forms of subordinated
financing, which the Company expects would require parent guarantees. To that end, the Company made an immediate equity contribution
to Jamalco upon acquisition, and has provided subsequent financing of costs for Jamalco to perform its activities in the ordinary course
of business. Thus, Management determined that Jamalco is considered to be a variable interest entity (“VIE”).

Within the variable interest model, the Company respectfully advises
the staff that we determined that the Company is the primary beneficiary of Jamalco, considering the guidance in ASC 810-10-25-38 to 25-38J.
[***].

ASC 810-10-25-38C, 25-38D and 25-38E provide context to kickout and
participating rights, shared power, and decisions made by multiple parties.

    Confidential Treatment of Certain Portions

of the Response to Comments 4 and 8 Requested by

Century Aluminum Company Pursuant to 17 C.F.R. 200.83

[CENX – 5]

January 17, 2025

Page 6

ASC 810-10-25-38C provides context for participating rights:

A reporting entity’s determination of whether it has
the power to direct the activities of a VIE that most significantly impact the VIE’s economic performance shall not be affected
by the existence of kick-out rights or participating rights unless a single reporting entity (including its related parties and de facto
agents) has the unilateral ability to exercise those kick-out rights or participating rights….

[***]. ASC 810-10-25-38D explains