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CORRESP
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filename1.htm

February 6, 2024

VIA EDGAR TRANSMISSION

Mr. John Coleman

Mr. Craig Arakawa

Ms. Melissa Gilmore

Mr. Kevin Woody

Division of Corporation Finance

Office of Manufacturing

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549-4631

 Re: National Steel Company (Companhia Siderúrgica Nacional – CSN)

Form 20-F for the fiscal year ended December 31, 2022

File No. 001-14732

Response to Staff Comment Letter Dated
January 23, 2024

Dear Mr. Coleman, Mr. Arakawa, Ms. Gilmore and Mr. Woody:

Reference is made to the response comment letter from the staff (the “Staff”)
of the U.S. Securities and Exchange Commission (the “SEC”) received by National Steel Company (Companhia Siderúrgica
Nacional – CSN) (the “Company” or “CSN”) on January 23, 2024, regarding the Company’s
response letter dated January 8, 2024, to the Staff comment letter dated December 7, 2023, with respect to the Company’s annual
report on Form 20-F for the fiscal year ended December 31, 2022, filed on April 27, 2023 (the “2022 Form 20-F”).
For your convenience, we have reproduced the Staff’s comments in italics and have provided responses immediately below.

The Company will improve its disclosure in accordance with the additional
information provided herein in future filings.

SEC Comment No. 1

Item 4. Information on the Company – General, page 17

Please provide us with a draft of your SK 1300 mineral property disclosure
that encompasses all of your proposed revisions. Based on your response we may have additional comment. Please note that summary disclosure
should include all mineral properties, for example iron ore and cement, and should clearly distinguish between material and non material
properties. The summary disclosure should include the information required by Item 1303(b) of Regulation S-K.

Companhia Siderúrgica Nacional

1

Av. Brigadeiro Faria Lima, 3400 – 20th Floor

Faria Lima Financial Center

04538-132 – São Paulo – SP

The individual property disclosure, which is only required for properties
that you have determined to be material, should include the information required by Item 1304 of Regulation S-K. The information
required for the individual property disclosure is more extensive and detailed in comparison. In your draft please clearly label each section
including Item 1303 Summary Disclosure, Item 1304 Individual Property Disclosure, and Item 1305 Internal Control Disclosure.

Response to Comment No. 1

Because CSN requires the input of a third-party qualified
person in order to prepare certain of the responses to the Staff’s comment letter, CSN will separately provide a revised draft of
its SK 1300 mineral property disclosure encompassing all proposed revisions within 20 business days of this letter.

Following is an overview of our material
mining properties:

Material Mining Properties

    Name of mining operation
    Location of the mining operation
    Type and amount of ownership interest (%)
    Operator
    Surface (Ha)
    Stage of the mining operation
    Permits
    Key condition of permit
    Type of mine/material
    Beneficiation plant and other installations

    Casa de Pedra
    Congonhas, MG
    79.75
    CSN Mineração
    2,516
    Production
    Yes
    EIA(1) and others
    Open Pit / Iron Ore
    Mining facilities and Pires

    Engenho
    Congonhas, MG
    79.75
    CSN Mineração
    344
    Production
    Yes
    EIA(1) and others
    Open Pit / Iron Ore
    Mining facilities and Pires

 (1) Environmental Impact Assessment – EIA. Permits or licenses have been obtained, are being renewed
or are being processed in accordance with current regulations.

Following is an overview of our non-material
mining properties:

Non-Material Mining Properties

    Name of mining operation
    Location of the mining operation
    Type and amount of ownership interest (%)
    Operator
    Surface (Ha)
    Stage of the mining operation
    Permits
    Key condition of permit
    Type of mine/material
    Beneficiation plant and other installations

    Bocaina
    Arcos, MG
    100
    CSN Cimentos Brasil
    342.9
    Production
    Yes
    (2)
    Open Pit / Limestone, Dolomite
    Bocaina Mining Facilities and Tin (ERSA)

    Pitimbu
    Alhandra, PB
    100
    CSN Cimentos Brasil
    746.7
    Production
    Yes
    (2)
    Open Pit / Limestone, Clay, Sand
    Pitimbu Mining Facilities

    Capoeira Grande
    Barroso, MG
    100
    CSN Cimentos Brasil
    93.4
    Production
    Yes
    (2)
    Open Pit / Limestone
    Capoeira Grande Mining Facilities

    Mata do Ribeirão
    Barroso, MG
    100
    CSN Cimentos Brasil
    129.7
    Production
    Yes
    (2)
    Open Pit / Limestone
    Mata do Ribeirão Mining Facilities

    Fazenda Campinho
    Pedro Leopoldo, MG
    100
    CSN Cimentos Brasil
    661.4
    Production
    Yes
    (2)
    Open Pit / Limestone
    Fazenda Campinho Mining Facilities

    Boa Vista
    Montes Claros, MG
    100
    CSN Cimentos Brasil
    432.9
    Production
    Yes
    (2)
    Open Pit / Limestone
    Boa Vista Mining Facilities

    Saudade
    Cantagalo, RJ
    100
    CSN Cimentos Brasil
    514.6
    Production
    Yes
    (2)
    Open Pit / Limestone
    Saudade Mining Facilities

    Miramar
    Caaporã, PB
    100
    CSN Cimentos Brasil
    983.7
    Production
    Yes
    (2)
    Open Pit / Limestone
    Miramar Mining Facilities

    Fernandinho
    Itabirito, MG
    79.75
    Minerios Nacional
    147.0
    Deactivated
    Yes
    -
    Open Pit / Iron Ore
    -

 (2) The key permissions to guarantee the respective reserves are: mineral concessions; environmental licenses;
and rights to use the property.

Companhia Siderúrgica Nacional

2

Av. Brigadeiro Faria Lima, 3400 – 20th Floor

Faria Lima Financial Center

04538-132 – São Paulo – SP

Iron Ore Mining Properties

Our iron ore business is conducted by our subsidiary CSN Mineração
in the state of Minas Gerais, within the area called the Iron Quadrangle. Casa de Pedra mine, Engenho mine and Fernandinho mine are our
open pit mines. Casa de Pedra mine and Engenho mine belong to the same mining complex and run their own transportation and shipping capabilities.
The mining complex comprises the Casa de Pedra Central Plant and the Pires Benefitiation Plant. Fernandinho mine, which is currently deactivated,
is located on the North side and, when it was active until 2015, it also ran its own transportation and shipping capabilities.

To complement its iron ore mining properties, CSN Mineração
runs the Itaguaí Port, located in the municipality of Itaguaí, state of Rio de Janeiro, and the Presidente Vargas Steel
Plant, in the municipality of Volta Redonda, also in the state of Rio de Janeiro.

The following map presents an overview of our iron ore operations:

Companhia Siderúrgica Nacional

3

Av. Brigadeiro Faria Lima, 3400 – 20th Floor

Faria Lima Financial Center

04538-132 – São Paulo – SP

Our iron ore properties comprise Casa de Pedra and Engenho (both material
properties) and Fernandinho (non-material property), as further described below:

Casa de Pedra Mine – Congonhas, MG

Casa de Pedra mine is our main iron ore mine. It is located in the municipality
of Congonhas, 80 km to the South of Belo Horizonte, the capital of the state of Minas Gerais. Its mining concession has no expiration
date and covers 2,516 hectares. Casa de Pedra is in full production stage.

Casa de Pedra mine has all the necessary permits for current operations,
and the authorization process related to its planned production expansion is running according to schedule. Related facilities, such as
waste piles and tailings dams, also comply with applicable legislation.

Casa de Pedra mine is an open pit operation with high grade hematite ore
type (iron grade of approximately 64%) mixed with a minor amount of Itabirite ore type (iron grade of approximately 30-60%). Mine occurrences
are represented by banded iron formations, varying from low grade (~Fe@30%) to medium/high grade types (~Fe@60%), and supergenous/hypogenous
hematite (Fe@64%), all varying from fresh to hard material types. Some types of mineralized covers are also mixed to feed the plant. The
geology framework is complex as a consequence of innumerous geological events that created an integrate grade variability scenario. For
this reason, mapping and drilling are always reinforced and are one of the work priorities at Casa de Pedra.

The Central Plant is fed with natural high grade run of mine, and the beneficiation
process comprises crushing, screening, and flotation. The Central Plant generates lump ore, sinter feed and pellet feed. The Pires beneficiation
plant is fed with low to medium grade in a dry beneficiation process.

All products from Casa de Pedra are transported by MRS’s railroad,
which transports iron ore to the Itaguaí maritime terminal in the state of Rio de Janeiro.

Engenho Mine – Congonhas, MG

Engenho mine covers 344 hectares and has been integrated in the Casa de
Pedra mining complex since 2012. Engenho mine production is constantly mixed with Casa de Pedra mine production, following the same process
route.

Companhia Siderúrgica Nacional

4

Av. Brigadeiro Faria Lima, 3400 – 20th Floor

Faria Lima Financial Center

04538-132 – São Paulo – SP

The following map sets forth a detailed illustration of Casa de Pedra mine
and Engenho mine locations:

Fernandinho Mine – Itabirito, MG

Fernandinho mine covers 147 hectares and has been integrated in the Casa
de Pedra mining complex since 2012. Fernandinho mine’s operations were deactivated in 2015 as part of an internal strategic decision.
In the future, additional geological, drilling and resource studies and estimations will be performed in order to update mineral resources
conversion to mineral reserves.

Companhia Siderúrgica Nacional

5

Av. Brigadeiro Faria Lima, 3400 – 20th Floor

Faria Lima Financial Center

04538-132 – São Paulo – SP

The following map sets forth a detailed illustration of Fernandinho mine
and its related facilities:

In addition to the mining properties detailed above, CSN Mineração
conducts initial exploration activities in the surrounding areas of our mining operations.

The following chart sets forth a summary of our iron ore resources and
reserves, updated to December 31, 2022, considering our ownership interest in each property:

    Measured mineral resources
    Indicated mineral resources
    Measured + Indicated mineral resources
    Inferred mineral resources

    Amount
    Grades/Qualities
    Amount
    Grades/Qualities
    Amount
    Grades/ Qualities
    Amount
    Grades/Qualities

    (Million tonnes)
    (% Fe)
    (Million tonnes)
    (% Fe)
    (Million tonnes)
    (% Fe)
    (Million tonnes)
    (% Fe)

    Iron ore:

    Casa de Pedra Mine
    344
    39.8
    1,210
    37.6
    1,554
    38.1
    1,209
    37.1

    Engenho Mine
    194
    40.2
    51
    46.9
    245
    41.6
    15
    43.5

    Fernandinho Mine
    42
    39.8
    49
    39.2
    92
    39.5
    50
    38.6

    Updated December/2022

Companhia Siderúrgica Nacional

6

Av. Brigadeiro Faria Lima, 3400 – 20th Floor

Faria Lima Financial Center

04538-132 – São Paulo – SP

    Proven mineral reserves
    Probable mineral reserves
    Total mineral reserves

    Amount
    Grades/Qualities
    Amount
    Grades/Qualities
    Amount
    Grades/Qualities

    (Million tonnes)
    (% Fe)
    (Million tonnes)
    (% Fe)
    (Million tonnes)
    (% Fe)

    Iron ore:

    Casa de Pedra Mine
    87
    39.4
    1,368
    41.0
    1,455
    40.9

    Engenho Mine
    11
    39.7
    168
    41.6
    179
    41.5

    *CSN considers an average price of US$95 per ton for the economic analysis.

    Updated December/2022

Cement Mining Properties

The following maps present the location of each non-material cement mining
property set forth below:

Bocaina Mine – Arcos, MG

Companhia Siderúrgica Nacional

7

Av. Brigadeiro Faria Lima, 3400 – 20th Floor

Faria Lima Financial Center

04538-132 – São Paulo – SP

Pitimbu – Alhandra, PB:

Mata do Ribeirão and Capoeira Grande – Barroso, MG:

Companhia Siderúrgica Nacional

8

Av. Brigadeiro Faria Lima, 3400 – 20th Floor

Faria Lima Financial Center

04538-132 – São Paulo – SP

Fazenda Campinho – Pedro Leopoldo, MG:

Boa Vista – Montes Claros, MG:

Companhia Siderúrgica Nacional

9

Av. Brigadeiro Faria Lima, 3400 – 20th Floor

Faria Lima Financial Center

04538-132 – São Paulo – SP

Saudade – Cantagalo, RJ:

Miramar – Caaporã, PB:

Each property includes a mine: (i) Elizabeth Plant – Pitimbu Mine;
(ii) Barroso Plant – Capoeira Grande Mine and Mata do Ribeirão Mine; (iii) Pedro Leopoldo Plant – Pedro Leopoldo Mine
(Fazenda Campinho); (iv) Cantagalo Plant – Cantagalo (Saudade Mine); (v) Caaporã Plant – Caaporã (Miramar Mine);
(vi) Montes Claros Plant – Mining complex of Montes Claros; and (vii) Arcos – Bocaina Mine.

Each cement mining property is owned 100% by us, and holds the respective
mining and property rights.

Companhia Siderúrgica Nacional

10

Av. Brigadeiro Faria Lima, 3400 – 20th Floor

Faria Lima Financial Center

04538-132 – São Paulo – SP

Each of these properties is operational. The key permissions to guarantee
the respective reserves are: mineral concessions; environmental licenses; and rights to use the property. Each of the property’s
mining types and mineralization styles, as well as respective processing plants and other available facilities, are set forth in the tables
above under the heading “Non-material Mining Properties.”

SEC Comment No. 2

Item 4. Information on the Company – General,
page 17

We note your response to comment one and we reissue the comment. Our
understanding is that Arcos is also a material property as you have filed a technical report summary for this property. If true,
please revise to include the required disclosure, including the location of your material property within 1 mile, using an easily
recognizable coordinate system to comply with Item 1304(b)(1)(i) of Regulation S-K.

Response to Comment No. 2

CSN reassessed its previous declaration and understands that Arcos is not
a material property within the meaning of § 229.1301 (Item 1301).

The following maps set forth the location of Arcos:

Companhia Siderúrgica Nacional

11

Av. Brigadeiro Faria Lima, 3400 – 20th Floor

Faria Lima Financial Center

04538-132 – São Paulo – SP

Companhia Siderúrgica Nacional

12

Av. Brigadeiro Faria Lima, 3400 – 20th Floor

Faria Lima Financial Center

04538-132 – São Paulo – SP

Companhia Siderúrgica Nacional

13

Av. Brigadeiro Faria Lima, 3400 – 20th Floor

Faria Lima Financial Center

04538-132 – São Paulo – SP

SEC Comment No. 3

Item 4. Information on the Company –
General, page 17

We note your response to comment 3. In the draft that you provide
for our review, please only include resource and reserve numbers that are attributable to you, as required by Item 1303(b)(3)(iii) of
Regulation S-K.

Response to Comment No. 3

The following table sets forth the resources and reserves numbers that
are attributable to CSN:

Casa de Pedra – summary of iron exclusive mineral resources as of
December 31, 2022:

    Engenho Mineral Resource Table (As of December 31, 2022)

    RESOURCES 2022 – 79.75% of CSN participation

    RESOURCE
    VOLUME (* 1000 m3)
    MASS (*1000 ton)
    Fe%
    SiO2%
    Al2O3%
    Mn%
    P%
    LOI%

    MEASURED
    71.95
    178.33
    40.23
    40.10
    0.66
    0.27
    0.04
    1.29

    INDICATED
    18.40
    44.22
    46.88
    29.14
    1.17
    0.55
    0.04
    1.62

    INFERRED
    6.14
    10.90
    43.45
    30.84
    2.09
    1.19
    0.06
    2.96

    TOTAL
    96.50
    233.46
    41.64
    37.60
    0.82
    0.37
    0.04
    1.43

Companhia Siderúrgica Nacional

14

Av. Brigadeiro Faria Lima, 3400 – 20th Floor

Faria Lima Financial Center

04538-132 – São Paulo – SP

SEC Comment No. 4

Item 4. Information on the Company