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August 6, 2025

BY ELECTRONIC SUBMISSION

United States Securities and Exchange Commission

Division of Corporation Finance

Office of Manufacturing

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 July 23, 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 July 23, 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 have reviewed your response to prior comment 1 and have the following comments. We note that you did not record any lease right-of-use
assets or intangible assets related to Jamalco’s right to use the Co-Tenancy Assets owned by the venture partner at no cost. Please
tell us your consideration of ASC 842 and ASC 360 in determining that no such assets were required to be recognized. In addition, confirm
to us the types of assets that are Co-Tenancy Assets, such as refining facilities, mining leases, and equipment.

We acknowledge the Staff’s comment and respectfully provide the
following explanation regarding our accounting considerations under Topic 842 – Leases. With respect to recognition of an
intangible asset, we evaluated accounting considerations under Topic 350 – Intangibles – Goodwill and Other.

The Co-Tenancy Assets include bauxite mining and alumina refining facilities,
the real property or interests therein on which such facilities are located, refinery equipment, rail equipment, material handling equipment,
transportation equipment, residue storage area equipment, and mineral reserves, which are used in connection with our joint activities.
The Jamalco operations utilize the Co-Tenancy Assets jointly owned by our subsidiary, General Alumina Jamaica Limited (GAJL), and the
Government of Jamaica (the JV Partner) at no cost pursuant to the joint venture agreement.

August 6, 2025

Page 2

The Company notes that it does not believe that it has a controlling
interest in a legal entity that owns the Co-Tenancy Assets, and that as a result, consolidation of something other than a legal entity
is precluded under US Generally Accepted Accounting Principles (“US GAAP”). The Company observes that for certain real estate
entities, proportionate interests in real estate may be treated as an equity method investment when certain conditions are met. Such guidance
does not apply to other entities nor does it apply to assets other than real estate and does not extend to full consolidation, and thus
does not apply to our direct interests in the Co-Tenancy Assets.

With respect to accounting for the Co-Tenancy Assets, we considered
EY’s Financial Reporting Developments on Consolidation, section 14.2, which states that proportionate consolidation is permitted
for 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. This was the case with respect to the Co-Tenancy Assets, and thus we proportionately
consolidated our undivided interest in the Co-Tenancy Assets.

In proportionately consolidating, the counterparty bears its own operating
costs through depreciation of its own basis in the Co-Tenancy Assets (which may be different from the Company’s), and through the
other costs and expenses the counterparty incurs in maintaining its portion of those assets, including their respective costs incurred
in financing and insuring the Co-Tenancy Assets.

With respect to undivided interests, it is inherent that the parties
must agree on a way to deploy the assets in which undivided interests are jointly held. However, the guidance does not require that the
party operating the assets on behalf of the two parties that jointly decided how to deploy them would have a lease or other intangible
asset for the undivided interests in the assets that it does not control.

Nonetheless, we considered whether other guidance might apply to the
arrangement related to Jamalco’s right to use the Co-Tenancy Assets owned by the JV Partner that would suggest accounting for a
lease or other intangible asset for the other undivided interest in the Co-Tenancy Assets.

Consideration of Topic 842:

In our contemplation of Topic 842, we consider the total of the Co-Tenancy
Assets as the unit of account for the assessment of a lease rather than the undivided interest of each individual owner. Under ASC 842-10-15-3,
a contract is or contains a lease if it “conveys the right to control the use of identified property, plant, or equipment (an identified
asset) for a period of time in exchange for consideration.” (emphasis added) This includes three criteria the arrangement
must possess to be a lease: 1) an identified asset, 2) the customer has the right to substantially all of the economic benefits from use
of the asset, and 3) the customer has the right to direct the use of the asset.

We considered this guidance and determined the following:

 · On a consolidated basis, the Company (through Jamalco) would be the potential
 ‘customer’ in this case of the JV Partner’s 45% undivided interests in the Co-Tenancy Assets. The Company (through its
other consolidated subsidiaries) already owns a 55% undivided interest in those same assets, which are recognized as owned.

 · ASC 842-10-15-16 states that a capacity portion of an asset is an identified
asset if it is physically distinct, or a capacity portion of an asset that represents substantially all of the capacity of the asset.

 o The Company notes that the JV Partner’s undivided interest in the Co-Tenancy Assets does not represent a physically distinct
portion of the assets.

August 6, 2025

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 o Additionally, the JV Partner’s interest is not substantially all of the capacity of the Co-Tenancy Assets. Substantially all
is generally interpreted to mean 90% or more. The JV Partner’s undivided interest is only 45% of the Co-Tenancy Assets, which thus
is not substantially all of the capacity portion of the Co-Tenancy Assets.

 o Because the JV Partner’s undivided interest in the Co-Tenancy Assets is neither physically distinct, nor substantially all of
the capacity of the Co-Tenancy Assets, management concluded that it would not meet the criteria to be an identified asset and thus could
not be leased under ASC 842.

 · Further, in respect to criteria 2 above, we noted that the Company would
also not have the right to substantially all of the economic benefits from use of the Co-Tenancy Assets, as it is required to distribute
JV Partner’s respective share of its undivided interest in the assets based on its ownership. That is, the Company only has the
right to retain benefits pertaining to its own 55% interest in the Co-Tenancy Assets, but has no right to the JV Partner’s benefits
pertaining to its 45% share. This is different from a sales-based royalty, in which a lessor is provided with a percentage based on third
party sales, which is viewed that the entity obtains 100% of the benefits and redirects a portion as a lease payment; in our case, by
contrast, this is an attribution of proportionate costs in a cost sharing arrangement. Cost sharing arrangements are common in extractive
industries. Additionally, the JV Partner’s 45% share of the alumina produced is transferred at cost providing limited economic benefit
to the Company. Thus, we would not obtain substantially all of the economic benefits from the use of the assets and thus Jamalco’s
right to use the JV partners’ Co-Tenancy Assets would not be a lease, even if there were an identified asset.

Finally, the joint venture partners do not receive cash or fixed non-cash
consideration for Jamalco’s use of the Co-Tenancy Assets. The joint venture partners receive their respective 55% or 45% share of
the direct output of the operations, which is variable and not determinable in advance of any given reporting period. Even if the allocation
to the joint venture partners of Jamalco’s output were to be treated as consideration for use of the Co-Tenancy Assets, such consideration
would not be deemed to be lease payments due to its variable nature. Under ASC 842-10-30-6, variable lease payments that do not depend
on an index or rate are excluded from the measurement of lease liabilities and right-of-use assets, and thus there would be no balance
sheet amounts recorded in respect of any potential lease.

 o ASC 842 is focused on the contractually enforceable terms and conditions of arrangements. This is even the case in arrangements between
related parties, as is provided for in ASC 842-10-55-12: “Leases between related parties should be classified in accordance with
the lease classification criteria applicable to all other leases on the basis of the legally enforceable terms and conditions of the lease.
In the separate financial statements of the related parties, the classification and accounting for the leases should be the same as for
leases between unrelated parties.” That is, the Company would not consider what “arm’s length” terms would be,
but rather account for the arrangements solely based on their contractual terms and conditions, to the extent ASC 842 were applicable.

Consideration of Topic 350:

The Company considered whether the right to use the remaining non-distinct
capacity portion of the Co-Tenancy assets should be reflected as an intangible asset. For context, because Jamalco is consolidated by
the Company, the Company already recognizes its proportionate ownership in 55% of the assets. Any rights between Jamalco and the Company
eliminate upon consolidation, so management considered whether the Company (including through Jamalco as a consolidated subsidiary) has
an intangible asset with regard to the JV Partner’s undivided interest that is used by Jamalco, even if such right does not meet
the definition of a lease.

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Generally, when a contract does not contain a lease but includes an
ongoing right to use or access an asset, US GAAP are not entirely clear as to how to account for such rights. This issue was raised in
the adoption of ASC 842 around land easements. In paragraph BC5 of the Background Information and Basis for Conclusions to Accounting
Standards Update 2018-01, Leases (Topic 842): Land Easement Practical Expedient for Transition to Topic 842, (“ASU 2018-01”),
the FASB acknowledged that diverse practice existed for land easements, and, among other observations, noted that “some entities
account for land easements paid over time as either executory contracts or finite life intangible assets, while others account for such
easements as leases.” Similarly, the Company believes diversity also exists in evaluating the right to use a non-distinct portion
of an asset.

Because the asset must continue to be made available, and the JV Partner
is equally responsible for ongoing repair and maintenance activities that are necessary for the assets to continue to function, and shares
jointly in their operating costs, the Company determined that there is an ongoing obligation for the JV Partner to continue to participate
in making their portion of the asset available in a usable condition. Therefore, the arrangements are then accounted for as executory
contracts.

Intangible assets are not typically recognized for executory contracts
unless there are off-market terms or there is an in-place contract value. We do not believe either of those to be present with respect
to Jamalco’s use of the Co-Tenancy Assets, as the JV Partner is still entitled to its proportionate share of the outputs created
with the Co-Tenancy Assets, and the Company has recognized its own cost in obtaining the undivided interest in the portion of the assets
it acquired. The fact that no cost is charged to either party is consistent with the fact that each party is contributing the economic
benefit of a portion of the jointly held asset toward a common goal in proportion to their undivided interest, and that neither party
is contributing the asset itself.

In addition to Topic 350, the Company considered the FASB’s Concepts
Statement No. 8—Conceptual Framework for Financial Reporting—Chapter 4, Elements of Financial Statements, which states
that an asset is a present right to an economic benefit. Although the Co-Tenancy assets are available for Jamalco's use within the bauxite
mining and alumina refining operations, we, through our consolidated JV or otherwise, do not receive any economic benefit from the JV
Partner’s 45% undivided interest in the Co-Tenancy Assets, as the respective 45% of alumina produced is distributed to our JV partner
at cost. Without an ability to derive economic benefit from the use of these assets, the fundamental criterion for asset recognition is
not met.

Accordingly, the Company does not believe there is a basis to recognize
an additional intangible asset to be recorded by the Company for the right to use the JV’s Partner’s proportionate share of
the Co-Tenancy Assets.

 2. We note that Jamalco has the right to use the Co-Tenancy assets at no cost. Please address the following:

 · Explain to us whether and how the joint venturers can monetize their respective rights in the Co-Tenancy Assets apart from their
interests in the joint venture or through the operations of the joint venture.

August 6, 2025

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We acknowledge the Staff’s comment and respectfully advise the
Staff that the Company asserts it has the ability to and will in the future monetize its interests in the Co-Tenancy Assets separate and
apart from the joint venture in a variety of circumstances. For example, with respect to equipment that may still have useful life but
is no longer suited for the joint venture’s operations for any reason, it is anticipated that the owners of the Co-Tenancy Assets
may sell such equipment, which may also include either the Company or the JV Partner agreeing to sell their undivided interest to the
other party. Such terms would have to be agreed to by both parties. If the subject equipment no longer has a useful life, it is expected
that the owners of the Co-Tenancy Assets may sell such equipment for scrap.

Importantly, consistent with undivided interest concepts, and different
from consolidation of a legal entity, the Company cannot unilaterally sell the Co-Tenancy Assets, even if it would immediately remit 45%
of the proceeds to the JV Partner. Instead, because the JV Partner has a joint, undivided interest in the asset, the JV Partner must also
participate in any decision to sell or dispose of the assets, in the same way that they had to agree to purchase those assets upon initial
acquisition. The fact that this aligns with the Jamalco ownership structure is operationally and economically advantageous and avoids
more complex cost-sharing that could otherwise result. But it is this direct ownership and joint participation that also demonstrates
a distinction from a consolidated legal entity over which the Company has a controlling financial interest.

We also note that either of the Company or the JV Partner, acting in
its individual capacity and not on behalf of Jamalco, would be permitted to transfer its undivided interest in the Co-Tenancy Assets to
a third party,