SecProbe.io

February 10, 2015

Via E -mail
Mr. Rogério Leme Borges dos Santos
Controller and Principal Financial Officer
National Steel Company
Av. Brigadeiro Faria Lima, 3,400 – 20th floor
04538 -132, São Paulo -SP, Brazil

Re: National Steel Company
Form 20 -F for Fiscal Year Ended December 31, 2013
Filed April 30, 2014
Response Letter dated January 26, 2015
File No. 1 -14732

Dear Mr. Santos:

We have reviewed your response and have the following comments.  In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.

Please respond to this letter within ten business days by amending your filing s, by
providing the requested  information, or by advising us when you will provide the requested
response.   If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your filings and the information you provide in response to
these  comments, we may have  additional comments.

Form 20 -F for Fiscal Year Ended December 31, 2013

Financial Statements

Note 9 -Investments, page FS -30

a) Events in 2013

1. We no te your response to comment 1 from our letter dated December 23, 2014.  In future
filings, please disclose the information you provided related to how you determined the
fair value of your remaining investment in TLSA.

Rogério Leme Borges dos Santos
National Steel Company
February 10, 2015
Page 2

 b) Changes in investments in joi nt ventures, associates, and other investments , page FS -31

2. We note your response to comment 2 and have the following additional comments.

 Please more fully explain the nature of the amounts you have identified as
“reclassifications.”   In this regard,  we note that paragraph 28 of IAS 28 indicates
that the investor’s share in the joint venture’s gains or losses resulting from
transactions between and entity and its joint venture is eliminated.   We therefore
do not understand your use of the term “reclas sification” and how you have
appropriately eliminated the resulting gains and losses specified in paragraph 28
of IAS 28.  Please explain.

 Reconcile these “reclassified” amounts to the information you have presented in
Note 19.

 Please explain why your r ollforward of your investment balance on page FS -31
includes the 542,711 total share of profits of joint ventures and associate if this
amount, as you appear to indicate in your disclosures, includes your share in the
joint ventures’ gains and losses resul ting from transactions with the joint ventures;
and

 Please tell us how you will revise future disclosures to better explain your
accounting.

3. We note your response to comment 3.  Please provide this clarifying information in your
future filings.

Note  10- Property, Plant, and Equipment, page FS -36

4. We note your response to comment 5.  Please provide this clarifying information in your
future filings.

Please respond to this letter within ten business days by amending your filing s, by
providing the r equested information, or by advising us when you will provide the requested
response.   If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your filing s and the information you provide in
response to these  comments, we may have  additional comments.

Rogério Leme Borges dos Santos
National Steel Company
February 10, 2015
Page 3

 You may contact Tracie Towner , Staff Accountant , at (202) 551 -3744 , or Jeanne Baker,
Assistant Chief Account ant, at (202) 551 -3691  if you have questions regarding comments on the
financial s tatements and related matters. You may contact  Jessica Dickerson , Staff Attorney , at
(202) 551 -3749  or me at (2 02) 551 -3355  with any other questions.

Sincerely,

 /s/ Terence O ’Brien

 Terence O’Brien
Branch Chief