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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)

Peter A. Trpkovski, Chief Financial
Officer

One South Wacker Drive

Suite 1000

Chicago, IL 60606

Tel: (312) 696-3101

April 25, 2025

BY ELECTRONIC SUBMISSION

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,
                                        2024

  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 March 14, 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 2
and 3. Specifically, the Company requests that the portions of its response to the Staff’s comments 2 and 3 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 – 8], [CENX – 9], [CENX – 11] and [CENX –
12] 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 of Certain Portions

of the Response to Comments 2 and 3 Requested by

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

[CENX – 1]

April 25, 2025

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.

Form 10-K for the Fiscal Year Ended December 31,
2024

Notes to the Consolidated Financial Statements

Note 2. Acquisition of Jamalco, page 64

 1. We have reviewed your response to prior comment 1. In your response to the fifth bullet point, you indicate
that you consolidate “the mineral properties and related raw and unfinished inventories through control of Jamalco, net of liabilities”
and proportionately consolidate “the undivided interests in individual fixed assets that are jointly held by the Company and the
Government of Jamaica.”

 • Provide us with your basis under U.S. GAAP for your hybrid method of consolidation for the same entity,
which appears to use both full and proportionate accounting methods. In doing so, expand on the nature of the legal entity or entities
involved and the specific assets with undivided interests.

COMPANY RESPONSE:

The Company acknowledges the Staff’s comment and respectively
advises the Staff that the Company is not applying a hybrid method of consolidation for the same entity. The Company is applying ASC 810
to determine that the Jamalco JV should be consolidated. Separate from the considerations under ASC 810, the Company is also applying
other accounting guidance to its ownership of an undivided direct interest in certain operating assets used in the business of the Jamalco
JV but held outside of the Jamalco JV. As such, the remainder of this response is intended to further clarify (i) the Company’s
conclusion that ASC 810 should be applied to the Jamalco JV and (ii) the accounting considerations and conclusions related to the
Company’s accounting for its undivided direct interest in the above-referenced operating assets held by General Alumina Jamaica
Limited (GAJL).

The Company’s wholly owned subsidiary, Century Aluminum Jamaica
Holdings, Inc. (CAJH), wholly owns General Alumina Holdings Limited (GAHL), which in turn, wholly owns GAJL, which is the direct
holder of a 55% interest in the Jamalco JV. CAJH, GAHL, GAJL and the Jamalco JV are viewed as separate legal entities within our consolidation.

We considered Deloitte’s Roadmap: Consolidation – Identifying
a Controlling Financial Interest (the “Roadmap”) in our evaluation noting the following:

Section 2.5 – Legal Entity - Throughout this Roadmap,
we refer to the entity that is analyzed for potential consolidation as the “legal entity.” Both the VIE model and the voting
interest entity model require a reporting entity to evaluate its involvement with any legal entity to establish

    Confidential Treatment of Certain Portions

of the Response to Comments 2 and 3 Requested by

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

[CENX – 2]

April 25, 2025

whether
consolidation of the legal entity is required. The assessment of whether a structure is a legal entity is a critical first step in the
overall consolidation analysis.

Section 2.5 of the Roadmap also
clarifies that a “legal entity” need not be incorporated or registered with a governmental agency or regulatory body as the
definition of a “legal entity” is intentionally broad and depends on specific facts and circumstances. We also evaluated
Section 3.2 – Legal Entities of the Roadmap which notes the following:

The
scope of the consolidation guidance in ASC 810-10 is limited to a reporting entity’s involvement with another legal entity. The
Codification defines “legal entity” relatively broadly; therefore, almost any legal structure that is used to own assets,
issue debt, or otherwise conduct activities would meet the definition of a legal entity. The
particular legal form of the entity (e.g., a corporation, a partnership, a limited liability company, a grantor trust, or other trust)
is not relevant to the determination of whether the entity is a legal entity. (emphasis added)

In
conducting its analysis of the above accounting guidance in its entirety, the Company concluded that, although the Jamalco JV is not
an incorporated legal entity, the Jamalco JV is considered to be a legal entity in the manner it conducts business (e.g.,
third parties contractual arrangements, financing ability, etc.) and thus would be evaluated for consolidation under U.S. GAAP pursuant
ASC 810.

Separate
from the Company’s 55% interest in the Jamalco JV, each of GAJL and the Jamaican Government also have an undivided, direct, proportionate
ownership interest (the “Undivided Interests”) in each of certain operating assets used in the business of the Jamalco but
owned directly by the Jamalco JV’s partners rather than by the Jamalco JV itself, including the land, buildings, equipment and
refinery and mining operation assets. In our comment response letter dated January 17, 2025, we previously referred to this group
of assets as “the Principle JV” Assets, but they are more accurately referred to as “Production Assets” since
the assets are not legally held by the Jamalco JV. The Company evaluated how to account for the
Undivided Interests separate from the Jamalco JV as the Production Assets are not held by the Jamalco JV and are not held by a legal
entity; in fact, the Production Assets and the Undivided Interests in the Production Assets are subject to a longstanding agreement (the
 “Asset Agreement”) between the holders of the Undivided Interests which, subsequent to the acquisition, are GAJL and the
Jamaican Government. The Asset Agreement outlines the terms of ownership and cooperation between GAJL and the Jamaican Government to
utilize the Production Assets to perform excavation and related activities in support of Jamalco’s operations. As such, the Company
concluded ASC 810 did not apply to the Production Assets as ASC 810-10-15-4 indicates that legal entities are subject to the consolidation
guidance and the Production Assets do not meet the definition of a “legal entity.”

The Company also considered whether
the Undivided Interests should be accounted for using the equity method of accounting pursuant to ASC 323 Investments – Equity
Method and Joint Ventures. The ASC Glossary defines an “undivided interest” as “an ownership arrangement in which
two or more parties jointly own property, and title is held individually to the extent of each party’s interest.”

    Confidential Treatment of Certain Portions

of the Response to Comments 2 and 3 Requested by

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

[CENX – 3]

April 25, 2025

Section 2.4.4 of Deloitte's Roadmap, Equity Method Investments
and Joint Ventures, indicates that “[b]ecause the guidance in ASC 323-10 applies only to ownership in the form of common
stock (or in-substance common stock), an investor that owns an undivided interest in each asset and is proportionately liable for its
share of each liability of an investee should not apply the equity method of accounting to such an investment.” That is, an undivided
interest in assets is not the same as an equity interest in a legal entity and would preclude application of the equity method.

Further, as neither consolidation under ASC 810 nor the equity method
under ASC 323 is the appropriate accounting treatment for the Company’s Undivided Interests, the Company further considered question
2.3.160 of KPMG LLP’s Handbook: Equity Method of Accounting (December 2024) (the “KPMG Guide”):

Background:
An undivided interest in an asset is an ownership arrangement in which two or more parties jointly own
the asset, and title is held individually to the extent of each party’s interest.

Interpretive
response: US GAAP does not specifically address how to account for an undivided interest
in non-real estate assets. However, in our experience, such an investor generally accounts for and presents an undivided interest in
a specified non-real asset as its proportionate share of the underlying asset. The investor classifies its share of the asset on its
balance sheet based on the nature of the asset (e.g. property) and recognizes in the income statement the individual components of its
results of operations (e.g. depreciation). An undivided interest in a specified asset generally is outside the scope of Topic 323 because
it represents a direct ownership of that individual asset – it is not an interest in an entity that holds the asset. A holder of
an undivided interest in a specified asset has proportional ownership of that asset.

The KPMG guide also states that “an investor applies the equity
method to an undivided interest in real property if that property is subject to joint control. Joint control exists when the approval
of two or more of the venturers is required for decisions about the financing, development, sale and operations of the real property.”

The Company additionally considered the following from the January 19-20,
2000, EITF meeting related to EITF00-1:

At
the January 19–20, 2000 EITF meeting, there was general agreement that if (a) an investor holds an undivided interest
in each asset, (b) an investor is proportionately liable for each liability, and (c) no separate legal entity exists, then
that investor should display on a proportionate gross basis those assets and liabilities in its balance sheet and the related results
of operations in its income statement. (emphasis added)

As the Production Assets do not represent real estate assets, the Company
concluded it should account for its Undivided Interest in the Production Assets based upon the proportion of the Undivided Interests that
it holds in each Production Asset, in a manner similar to proportionate consolidation consistent with the EITF guidance cited above.

 • Tell us how Jamalco specifically impacts your financial statements, including the line items and consolidation
methods applied to related items on your statements of

    Confidential Treatment of Certain Portions

of the Response to Comments 2 and 3 Requested by

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

[CENX – 4]

April 25, 2025

operations and
balance sheet. Clarify which statement of operations line items include proportionate amounts and describe the nature of each item included.
Specify how and where you record depreciation expense related to the undivided interests in individual fixed assets.

COMPANY RESPONSE:

As
previously stated, the Company fully consolidates the Jamalco JV’s results of operations in accordance with ASC 810. In addition,
the Company records its Undivided Interests in the Production Assets, which includes the land, buildings, equipment, refinery and
mining operation assets, as a component of Property, plant and equipment – net. The depreciation expense related to the Company’s
Undivided Interests in the Production Assets is a component of Cost of goods sold. This is consistent with the guidance in question 2.3.160
in the KPMG Guide cited above.

The following tables indicate with an “X” the financial
statement line items that include impacts from the Jamalco JV within the statement of operations and balance sheet:

    Confidential Treatment of Certain Portions

of the Response to Comments 2 and 3 Requested by

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

[CENX – 5]

April 25, 2025

    Confidential Treatment of Certain Portions

of the Response to Comments 2 and 3 Requested by

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

[CENX – 6]

April 25, 2025

In accordance with ASC 810-10-50-1A, the Company discloses separately
on the face of the consolidated financial statements (1) consolidated net income and consolidated comprehensive income and (2) the
related amount attributable to the Government of Jamaica as a noncontrolling interest and the related amount attributable to the Company.
The Net income attributable to noncontrolling interest represents the Government of Jamaica’s proportionate share of the Jamalco
JV’s net income, in accordance with the JV agreement.

 • In regards to the Jamalco purchase price acquisition on page 64 of your fiscal year 2024 Form 10-K,
tell us and quantify the specific assets or liabilities, if any, that are recorded on a proportionate basis.

COMPANY RESPONSE:

All of the assets and liabilities enumerated in the purchase price
allocation of Jamalco were fully consolidated upon acquisition. The Company acquired $217.2 million of property, plant and equipment,
$190.5 million of which represent the Company’s Undivided Interest in the Production Assets.

Note 19. Business Segments, page 97

 2. Regarding the analysis of similar economic characteristics provided in your response to prior comment
2, please provide us with a revised analysis that includes the following information:

 • The underlying historical and projected financial and other data you considered in concluding that the
aggregated operating segments have similar economic characteristics under ASC 280-10-50-11. Include quantitative data for revenues and
any measures of segment profitability you considered, by year, for each operating segment. Explain how any projections that you considered
were developed as well as