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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

February 24, 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 February 9, 2025, 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
1 and 2. Specifically, the Company requests that the portions of its response to the Staff’s comments 1 and 2 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 “[***]”(on the pages marked [CENX-4], [CENX-9] and [CENX-10] of the filed version of this
letter) 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 1 and 2 Requested by

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

[CENX – 1]

February 24, 2025

 Page 2

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

Notes to the Consolidated Financial Statements

2. Acquisition of Jamalco, page 60

 1. We
                                            note your response to prior comment 4 and have the following comments:

 · Please
                                            provide us with a more detailed analysis of your primary beneficiary determination, including
                                            identification of the activities that most significantly impact Jamalco's economic performance
                                            and a description of how decisions are made regarding each activity. Provide us with a copy
                                            of the agreement that sets forth the rights and obligations of each investor.

COMPANY RESPONSE:

The Company acknowledges the Staff’s comment and
respectfully advises the Staff that the Company carefully considered the guidance in ASC 810-10-25-38 to 25-38J in connection with its
primary beneficiary analysis with respect to Jamalco. The Company also acknowledges the Staff’s request to be provided with a copy
of the Jamalco JVA and the Company respectfully advises the Staff that it will provide such document as a supplement to this letter.

ASC 810-10-25-38 states that a reporting entity with a
variable interest in a VIE should consolidate that VIE if it has a controlling financial interest as the primary beneficiary. ASC 810-10-25-38A
clarifies that in order to have a controlling financial interest in a VIE, a variable interest holder must have both of the following
attributes:

 o The
                                            power to direct the activities of a VIE that most significantly affect its economic performance
                                            (“power”); and

 o The
                                            obligation to absorb losses of the VIE or right to receive benefits from the VIE that could
                                            potentially be significant to the VIE (“benefits”).

The Company has the obligation to absorb the majority of
losses of Jamalco and receive the majority of benefits from Jamalco that are significant through its 55% interest in Jamalco. Thus, the
Company receives benefits from Jamalco.

When assessing whether the Company has power over Jamalco,
the Company considered the following four step analysis:

 1. Consider the purpose and design.

 2. Identify the activities that most significantly impact economic performance.

 3. Determine how decisions about the significant activities are made
                                            and the party or parties that make them.

 4. Identify the party or parties that make the decisions about the significant
                                            activities, including consideration of kick-out rights, participating rights, and/or protective
                                            rights.

Confidential Treatment of Certain Portions

of the Response to Comments 1 and 2 Requested by

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

[CENX – 2]

February 24, 2025

Page 3

Step 1: Consider purpose and design

ASC 810-10-25-25 includes considerations for determining
the purpose for which a legal entity was created. This can include the activities of the legal entity, the terms of the contracts the
legal entity has entered into, the nature of the legal entity’s interests issued, how the legal entity’s interests were negotiated
with or marketed to potential investors, and which parties participated significantly in the design or redesign of the legal entity.

Once the purpose has been determined, the Company should
identify the nature of risks that Jamalco was designed to distribute. ASC 810-10-25-24 provides details of the nature of the risks that
cause variability, such as credit risk, interest rate risk, foreign currency exchange risk, commodity price risk, equity price risk,
and operations risk.

Jamalco was formed for the purpose of bauxite mining and
alumina production in Jamaica. Therefore, Jamalco was designed in order to distribute operations risk related to the mining and alumina
production operations (“Jamalco operations”), as well as commodity price risk.

Step 2: Identify the activities that most significantly
impact the VIE’s economic performance

While considering the purpose and design of Jamalco, the
Company identified the following activities as those that most significantly impact the economic performance of Jamalco:

 o Day-to-day
                                            management of Jamalco operations, such as prioritizing activities for executing operating
                                            plans and maintenance activities

 o Negotiating
                                            raw material and operating supply contracts and managing supply chain functions with suppliers
                                            and vendors

 o Determining
                                            operating and capital budgets

 o Hiring/firing/compensating
                                            all operations personnel

 o Making
                                            financing decisions for the deployment of capital from operations as well as assessing the
                                            need and timing of proposed capital calls

While Jamalco engages in various activities that impact
the business, this subset of activities is considered to be the most significant, as they directly and meaningfully affect the economic
performance of the entity (that is, the revenues, expenses, margins, cash flows, financial position) and the activities that have the
most significant impact on the entity which are operations and commodity price risk.

Confidential Treatment of Certain Portions

of the Response to Comments 1 and 2 Requested by

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

[CENX – 3]

February 24, 2025

Page 4

Steps 3 and 4: Identify how decisions about significant
activities are made and the party that makes them

Pursuant to ASC 810-25-38 to 38B, after the activities
that most significantly impact Jamalco’s economic performance have been identified, the Company must determine how decisions about
the significant activities are made and evaluate whether it has power to direct those activities. Management considered that power may
be exercised through voting rights of the equity holders, the board of directors (on behalf of the equity holders), a management contract,
or a combination of these factors.

[***].

 · In
                                            future filings, disclose within the liquidity section of MD&A any material known demands
                                            or commitments related to the funding of Jamalco.

COMPANY RESPONSE:

The Company acknowledges the Staff’s comment and
respectfully advises the Staff that the Company will make the requested additional disclosures within the liquidity section of the MD&A
in future filings, as applicable.

 · Provide
                                            in future filings all material applicable disclosures set forth in ASC 810-10-50-2AA through
                                            -22.

COMPANY RESPONSE:

The Company acknowledges the Staff’s comment and
respectfully advises the Staff that the Company will enhance its disclosures, specifically reconsidering ASC 810-10-50-2AA through -22
in future filings, as applicable.

Confidential Treatment of Certain Portions

of the Response to Comments 1 and 2 Requested by

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

[CENX – 4]

February 24, 2025

Page 5

 · Considering
                                            the acquisition date recognition guidance of ASC 805-30-25-2 and since the nominal purchase
                                            price appears to suggest that a bargain purchase gain existed as of such date, tell us in
                                            further detail how you determined that the guidance in ASC 805-30-25-4 and ASC 805-30-30-5
                                            allows for deferral of bargain purchase gains until the end of the measurement period.

COMPANY RESPONSE:

The
Company acknowledges the Staff’s comment. As discussed in the Company’s letter dated January 17, 2025, the Company
considered the guidance within ASC 805-30-25-2 as well as the guidance within ASC 805-30-25-4. That guidance specifically states:

“Before recognizing a gain on a bargain purchase,
the acquirer shall reassess whether it has correctly identified all of the assets acquired and all of the liabilities assumed and shall
recognize any additional assets or liabilities that are identified in that review.” (emphasis added).

Accordingly, in light of the complexity of this acquisition
and notwithstanding the fact that the transaction had the potential to result in a bargain purchase gain, the Company deferred the amount
of the preliminary bargain purchase gain in order to continue to assess whether the Company had identified all of the assets and liabilities
acquired pursuant to ASC 805-30-25-4, rather than immediately recognizing the gain upon the acquisition pursuant to ASC 805-30-25-2.

In
reaching this conclusion, the Company was particularly sensitive to the complex and detailed nature of the valuation work in the context
of a distressed acquisition as well as the potential risks associated with publicly recognizing a gain only then to materially reduce
or alter that amount in subsequent periods if additional information became available during the measurement period that existed at the
time of the acquisition. As the Company’s process for completing its accounting for its business combination was ongoing,
the Company also considered ASC 805-30-30-5, which indicates that before a bargain purchase is recognized, an acquirer should reassess
whether it has appropriately identified and measured all of the assets acquired and liabilities assumed. In accordance with ASC 805-30-30-4
and 30-5, then, the Company determined it would be inappropriate to recognize a bargain purchase gain during the measurement period until
that process was complete. As of December 31, 2023, the Company continued to evaluate the assets and liabilities identified, including
ensuring environmental liabilities, long-lived assets, asset retirement obligations, and other contingencies had been fully assessed,
and the valuation techniques were appropriate. Additionally, while the Company acknowledges that the nominal purchase price may have
indicated a bargain purchase was possible, the Company did not believe a “piecemeal” approach to gain recognition was consistent
with the guidance in ASC 805-30-25-4, or the guidance in ASC 805-30-30-5 and so deferred the entire gain until the full reassessment
of assets acquired and liabilities assumed had been completed.

The Company also notes that its treatment was also consistent
with the treatment afforded other gain contingencies in ASC 450-30-25-1, which requires gains to be deferred until they are realized
or realizable. That is, the Company deferred the bargain purchase gain until after a reassessment of the purchase allocation had been
performed to ensure the gain was realizable.

The
Company also considered guidance in Deloitte’s Roadmap: Business Combinations (December 2024) - Section 5.2, which discusses
two approaches to a provisional bargain purchase gain – (1) recognition on a preliminary basis or (2) deferral until
the accounting for the acquisition is complete – noting that either approach is acceptable. Consistent with this guidance, the
Company made a policy election to defer the credit until the process was complete. The Company transparently disclosed the policy
choice, the gain deferred as of December 31, 2023, as well as the preliminary nature of the purchase price allocation.

Confidential Treatment of Certain Portions

of the Response to Comments 1 and 2 Requested by

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

[CENX – 5]

February 24, 2025

Page 6

In April 2024, the Company completed its purchase
price allocation, including obtaining final valuation reports to reassess the assets acquired and liabilities assumed in connection with
finalization of its March 31, 2024, reporting and close cycle. The Company also notes that, as a result of finalizing these procedures,
the bargain purchase was, in fact, reduced by approximately $28 million compared to the amount deferred at December 31, 2023, highlighting
the uncertainty inherent in the preliminary amounts. At this point the Company was able to close the measurement period and conclude
that it had appropriately measured the bargain purchase gain, including to reflect consideration of all available information for all
identified assets acquired and liabilities assumed as of the acquisition date. As such, the Company recognized the bargain purchase gain
in i