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June 3, 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 March 31,
2025

  Response dated May 19, 2025

  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 May 19, 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.

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 note from your response to prior comment 1 your consideration of the January 19- 20, 2000
EITF meeting which indicates an “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.” Although one of the specified conditions to apply proportionate
consolidation is that “no separate legal entity exists,” you have concluded the “Jamalco JV” represents a legal
entity consolidated under ASC 810. We further note that the guidance in ASC 810-10-45-14 indicates proportionate consolidation does not
apply to entities in an extractive industry “if its activities involve related activities such as refining, marketing, or transporting
extracted mineral resources.” Please explain to us why you believe proportionate consolidation of the “Production Assets”
is appropriate given they appear to be held through a legal entity and involve refining activities.

We acknowledge the Staff’s comment and respectfully note that,
as it relates to its operations in Jamaica, the Company has two distinct types of interests which it separately accounts for:

 · A controlling financial interest in the Jamalco JV, a legal entity. As a result of its controlling financial interest, the Company
fully consolidates the results of operations and the financial position of the Jamalco JV in accordance with the provisions of ASC 810
and recognizes a noncontrolling interest in respect of the interest held by the other equity interest holder in the Jamalco JV; and

June 3, 2025

Page 2

 · A direct, undivided interest in property, equipment, and refinery and mining operations assets (the “Production Assets”).
These Production Assets are not held or owned by the Jamalco JV, or by any intermediate legal entity for that matter, and therefore the
direct, undivided interest that the Company owns in each of the Production Assets is accounted for by the Company separately from the
Company’s accounting for its controlling financial interest in the Jamalco JV.

We acknowledge and agree with the Staff’s comment that the guidance
in ASC 810-10-45-14 indicates proportionate consolidation does not apply to entities in an extractive industry “if its activities
involve related activities such as refining, marketing, or transporting extracted mineral resources.” We respectfully note, however,
that the guidance in ASC 810-10-45-14 relates specifically to scenarios in which proportionate consolidation may be an acceptable alternative
to the equity method of accounting in instances in which the equity method of accounting would otherwise apply. The context and intent
of this guidance is indicated within EITF 00-1 (the “EITF”), which is the original pre-codification guidance of paragraph
ASC 810-10-45-14. Specifically, paragraph 3 therein states the following: “The issue is whether there are circumstances in which
proportionate gross presentation is appropriate under the equity method of accounting for an investment in a legal entity (emphasis
added).”

The specific facts and circumstances that exist with respect to the
Company’s interests in the Production Assets are therefore not those that are contemplated by ASC 810-10-45-14, given that such
interests represent direct, undivided ownership interests in the Production Assets themselves (instead of, for example, ownership interests
in a legal entity that would otherwise be subject to the equity method of accounting, as contemplated by paragraph 3 of the EITF). More
specifically, these Production Assets are not held or owned by the Jamalco JV. Rather, the Company’s interests in each of these
Production Assets are held directly by the Company.

In further support of the Company’s accounting for the undivided
interests in the Production Assets, the Company respectfully advises the Staff that Section 14.2 of EY’s Financial Reporting
Developments on Consolidation (EY Consolidation FRD) notes the following [emphasis added]:

Proportionate consolidation is permitted only
for the following:

 1) Investments in unincorporated legal entities (e.g., partnerships) in the extractive or construction industries that would otherwise
be accounted for under the equity method of accounting (i.e., a controlling financial interest does not exist). To determine whether a
legal entity (e.g., an LLC) represents an unincorporated legal entity for purposes of determining whether proportionate consolidation
is permitted, the investor should consider whether the governance provisions are more akin to a partnership or corporation (see section
7.3.1.6). Based on discussions with the SEC staff, we understand that the SEC staff shares this view.

 2) Ownership of an undivided interest in an asset when each owner is entitled only to its pro rata share of income and expenses and
is proportionately liable for its share of each liability. However, real estate entities subject to ASC 970-323 that own an undivided
interest in real property that is under joint control (as defined in US GAAP) must use the equity method of accounting.

June 3, 2025

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Under proportionate consolidation, the investor presents
its proportionate share of the investee’s revenues and expenses in each major revenue and expense caption of the investor’s
income statement. Also, the investor may present its proportionate share of the investee’s assets and liabilities separately in
each major asset and liability caption of the investor’s balance sheet. […]

We note that the facts and circumstances surrounding the Company’s
ownership of undivided interests in the Production Assets align with (2) above. Therefore, the Company accounts for its undivided
interest in each of 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.

For the avoidance of doubt, we wish to clarify that, separately from
the Company’s ownership of direct, undivided interests in the Production Assets, the Company also holds a 55% interest in the Jamalco
JV, through which it fully consolidates all assets held by the Jamalco JV (which, as explained above, do not include the Production Assets).
As the Staff noted, we have concluded the Jamalco JV is a legal entity, subjected it to the consolidation model in ASC 810, and determined
that the Company has a variable interest in the legal entity that is a variable interest entity. The Company concluded it is the primary
beneficiary of the Jamalco JV and fully consolidates the Jamalco JV on that basis.

Accordingly, the Company respectfully submits that it is properly accounting
for its respective interests in the Jamalco JV (full consolidation) and in the direct, undivided interests in the Production Assets (proportionate
consolidation).

 2. We note your disclosure on page F-101 of the carrying amounts and flows classification of the
consolidated Jamalco VIE assets and liabilities included in the consolidated balance sheets. Please explain to us your consideration of
ASC 810-10-50-2AA(d) regarding providing financial statement users with an understanding of how your involvement with the VIE additionally
affects your financial performance and cash.

We acknowledge the Staff’s comment and respectfully advise the
Staff that we will provide additional disclosures in future filings with respect to how the Company’s interest in Jamalco affects
the Company’s financial position, financial performance, and cash flows. With respect to financial performance, we note the Company
disclosed the following in its 2024 form 10-K: “For the twelve months ended December 31, 2023, Jamalco contributed $150.3 million
to our total revenues and a loss of $41.1 million to our total earnings. In connection with the acquisition, the Company incurred approximately
$1.4 million of transaction costs for the twelve months ended December 31, 2023, which are included in selling, general and administrative
expenses on the Consolidated Statements of Operations.”

In future filings, we will expand our disclosures to include the following
information to better inform users of our financial statements of the effects of the Jamalco VIE’s involvement on performance and
cash flow:

Jamalco mines and refines bauxite and constructs capital
assets that are paid for and owned by the joint venture partners. While the Company consolidates the full results of Jamalco, the Company
owns a 55% ownership interest in Jamalco and is responsible for funding 55% of its operating costs and capital requirements and does not
provide additional financial support beyond its equity interest. The Company obtains direct ownership of our 55% share of Jamalco’s
outputs and purchases the remaining 45% of the output from the Government of Jamaica. Through direct ownership and purchase, 100% of Jamalco’s
output is either retained and utilized in the Company’s business operations or sold by the Company. The Company’s consolidated
statement of cash flows reflects 100% of cash flows related to the Jamalco operations. The Company receives cash proceeds from the Government
of Jamaica for its 45% interest of the Jamalco operating costs and capital requirements.

June 3, 2025

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Note 19. Business Segments, page 97

 3. We note your statement in response to prior comment 2 that, beginning with the quarter ended March 31,
2025, you believe that none of your four prior operating segments meet the definition of an operating segment and, as a result, you have
determined that you currently have only one operating segment. Please address the following comments related to the identification of
your operating segments:

 · Provide us with details about your management structure and how your company is organized. In doing
so, provide us with a detailed organizational chart that extends to all managers that oversee the components previously identified as
operating segments, including a description of the roles and responsibilities of each individual. Tell us each of the individuals who
report to the Chief Operating Decision Maker (“CODM”).

We acknowledge the SEC’s comment and respectfully advise the
Staff that the Company applies the guidance prescribed in ASC Topic 280, Segment Reporting, in its determination that it has a single
operating segment and single reportable segment. This conclusion is supported by the way in which the Company conducts its business activities
and the way in which the Chief Operating Decision Maker (“CODM”) views and manages the business. The Company is organized
as a holding company, with each of the previously identified operating segments (as well as the Jamalco JV and our Vlissingen business,
the “business units”) owned by a separate subsidiary. The CODM makes resource allocation decisions on a consolidated basis.
That is, the Company’s business is not divided into multiple components for purposes of reviewing operating results for assessing
performance or allocating resources.

ASC 280-10-50-1 defines an operating segment as a component of a public
entity that has all of the following characteristics:

 · It engages in business activities from which it may earn revenues and incur expenses (including revenues and expenses relating to
transactions with other components of the same public entity).

 · Its operating results are regularly reviewed by the public entity’s CODM to make decisions about resources to be allocated to
the segment and assess its performance.

 · Its discrete financial information is available.

We’ve included the following organizational chart that extends
to all managers that oversee the Company’s business units (“Managers”) to visually represent the structure of our organization.

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Jesse E. Gary is our President and Chief Executive Officer (“CEO”)
and is the Company’s CODM. Mr. Gary has six direct reports who oversee specific functional areas. Collectively, the CODM’s
direct reports are known as the “Executive Management Team”. These direct reports include the following:

 (1) Executive Vice President, Chief Financial Officer and Treasurer

 (2) Executive Vice President, Global Operations

 (3) Executive Vice President, General Counsel and Secretary

 (4) Senior Vice President, Strategy and Business Development

 (5) Senior Vice President, Chief Commercial Officer

 (6) Senior Vice President, Human Resources

Set forth below is a list of the Managers, including a description
of the roles and responsibilities of each Manager that oversees components that were previously identified as operating segments. None
of the Managers currently reports or previously reported directly to our CODM.

    Title
    Responsibilities

    Vice President of Operations, Americas
    Oversees all operations in the U.S. and Jamaica. Reviews budget/forecast for U.S. and Jamaica facilities

    Manager of Grundartangi
    Manages day-to-day operations of the Grundartangi facility. Prepares budget/forecast for facility and explains variances in actuals with support from local operations and finance teams.

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    Manager of Sebree
    Manages day-to-day operations of the Sebree facility. Prepares budget/forecast for facility and explains variances in actuals with support from local operations and finance teams.

    Manager of Mt. Holly
    Manages day-to-day operations of the Mt. Holly facility. Prepares budget/forecast for facility and explains variances in actuals with support from local operations and finance teams.

    Manager of GAJL/Jamalco
    Manages day-to-day operations of the Jamalco facility. Prepares budget/forecast for facility and explains variances in actuals with support from local operations and finance teams.

    Manager of Vlissingen
    Manages day-to-day operations of the Vlissingen facility. Prepares budget/forecast for facility and explains variances in actuals with support from local operations and finance teams.

Our CODM has responsibility for executing the Company’s strategic
plan and for evaluating the performance of the Company’s business as a whole.

 · Tell us in sufficient detail how you determined your chief executive officer represents the sole
member of the CODM function.

In consideration of ASC 280-10-50-5 through 50-9, management assessed
the CODM determination to be the person or persons who are making the key operating decisions for the Company. We also considered whether
other executive officers, including our Executive Vice President, Global Operations and Mr. Gary’s other direct reports, together
with Mr. Gary were a CODM function as described in ASC 280-10-50-5. While these executive officers are an integral part of the Company’s
management team and are the persons directly accountable for executing and carrying out