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	May 16, 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
May 2, 2024

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

Reference is made to the 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 May 2, 2024, regarding the Company’s
annual report on Form 20-F for the fiscal year ended December 31, 2022, filed on April 27, 2023 and amended on April 25, 2024. For your
convenience, we have reproduced the Staff’s comments in italics and have provided responses immediately below.

SEC Comment No. 1

Item 4. Information on the Company, page 1

Please provide an updated reconciliation with depletion due to
mining activities for your resources/reserves as reported in the most recent year compared to the prior year, as required by Item 1304(e)
of Regulation S-K and confirm that you will include this reconciliation in subsequent annual filings. Note that this is only required
for material properties.

Response to Comment No. 1

The following table sets forth a reconciliation
with the depletion of mineral resources (exclusive of reserves) for Casa de Pedra mine and Engenho mine in each of 2022 and 2023, considering
our ownership interest of 78.2% as of December 31, 2021 and 79.8% as of December 31, 2022 and 2023:

    As of

    December 31, 2021

    2022
    Depletion

    2022
    Net Difference

    As
    of December 31, 2022

    2023 Depletion

    2023
    Net Difference

    As
    of

    December 31, 2023

    Mineral Resources (million tons)
    2,895
    (22)
    1.17%
    2,929
    (28)
    (0.96)%
    2,901

_________________

Note: Figures included in this table have been subject to rounding
adjustments. Accordingly, figures shown as totals may not represent an arithmetic sum of the figures that precede them.

The following table sets forth a reconciliation
with the depletion of mineral reserves for Casa de Pedra mine and Engenho mine in each of 2022 and 2023, considering our ownership interest
of 78.2% as of December 31, 2021 and 79.8% as of December 31, 2022 and 2023:

    As of

    December 31, 2021

    2022
    Depletion

    2022
    Net Difference

    As
    of December 31, 2022

    2023 Depletion

    2023
    Net Difference

    As
    of

    December 31, 2023

    Mineral Reserves (million tons)
    1,626
    (24)
    0.48%
    1,634
    (28)
    (1.71)%
    1,606

_____________

Note: Figures included in this table have been subject to rounding
adjustments. Accordingly, figures shown as totals may not represent an arithmetic sum of the figures that precede them.

We will include updated annual reconciliation with depletion
due to mining activities for our mineral resources and reserves in material mining properties in future filings.

SEC Comment No. 2

Item 4. Information on the Company, page 1

Please provide proposed disclosure of non-material
resource and reserve tables which includes the following, as required by Item 1303(b)(3) of Regulation S-K:

 • the point of reference in which reserves and resources are calculated, such as in-situ, mill feed, saleable product, etc; and

 • the currency with respect to the pit optimization parameters on page 26.

Response to Comment No. 2

The point of reference in which our reserves and
resources are calculated for our non-material properties is in-situ.

We will disclose the point of reference in which our
reserves and resources are calculated in future filings.

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

The following table sets forth the pit optimization parameters
for our non-material properties in millions of Brazilian reais.

    Alhandra

    Arcos

    Barroso

    Caaporã

    Cantagalo

    Montes Claros

    Pedro Leopoldo

    Diesel/Gasoline
    3.783
    11.692
      5.276
      2.841
      2.084
      1.842
     1.968

    Electrical Energy Variable
    0.453
    2.920
     1.930
     0.679
       0.332
         0.416
       1.008

    Wear Parts
    -
     -
      344
    0.004
        0.073
      0.098
    0.226

    Production and Distribution Material
    2.450
     3.546
      2.036
       1.743
       0.788
        0.999
     1.536

    Outsourced Activities
         -
      -
    3.910
     2.574
     0.515
    2.509
     1.090

    Mining Concessions and Royalties
        -
        -
     1.218
      0.773
      0.461
       0.452
     0.420

    Variable Cash Cost
       6.687
    18.158
      14.714
     8.614
     4.253
      6.316
      6.249

    Electrical Energy Fixed
        -
           -
         429
     0.221
      0.093
      0.099
     0.361

    Labor Expenses Own
      4.049
      14.747
      7.080
      4.781
    3.372
     3.521
     3.221

    Third Party Services
        1.247
      22.365
     4.206
      1.076
       0.297
    0.507
      1.822

    Maintenance Material
     1.541
         2.503
     2.748
    0.837
      0.372
        0.321
    1.813

    Other Cost
       0.165
      5.055
      2.827
     0.331
     0.053
    0.101
      0.213

    Fixed Cash Cost
       7.002
      44.668
    12.971
     4.541
     3.292
    3.197
     6.161

    Cash Cost
     13.689
     62.826
      27.684
     13.155
    7.544
    9.514
     12.410

    Depreciation and Amortization
       0.387
    30.452
    22.383
     6.710
     4.243
    1.257
     2.590

    Cost of Goods Sold
      14.076
     93.278
    50.068
     19.934
     11.787
    10.770
      15.049

    Price*
    ~10%
    ~10%
    ~10%
    ~10%
    ~10%
    ~10%
    ~10%

_____________

 * With respect to price parameters, we assume a margin of 10% over total cost of goods
sold, since we do not conduct direct sales. With respect to commodity price, pricing dynamics for cement are a function of local supply
and demand and are not, like other commodities such as steel and iron ore, pegged to an index or to global commodity prices. In addition,
cement prices take into account the costs of cement plants, which may vary by plant and by company.

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Form 20-F for the year ended December 31, 2023:

The following table sets forth the pit optimization parameters
for our non-material properties in millions of Brazilian reais:

    Alhandra

    Arcos

    Barroso

    Caaporã

    Cantagalo

    Montes Claros

    Pedro Leopoldo

    Plant

    Fuel
    2.542
    11.302
    5.781
    2.555
    2.148
    2.132
    2.585

    Electric Energy
    0.406
    2.201
    1.678
    0.340
    0.187
    0.283
    0.845

    Other Variable Costs

    2.498

    3.177

    2.968

    2.444

    0.927

    1.905

    3.257

    Variable Cost
    5.445
    16.680
    10.426
    5.339
    3.261
    4.320
    6.687

    Labor Expenses
    6.081
    17.574
    3.421
    2.044
    2.920
    1.713
    1.980

    Third Party Services
    2.054
    12.868
    4.415
    1.516
    0.187
    1.653
    0.131

    Maintenance (Material and Services)
    2.990
    16.598
    3.923
    0.852
    0.284
    0.354
    2.236

    Other Fixed Costs

    (0.296)

    4.549

    (2.805)

    0.217

    0.132

    0.169

    0.068

    Fixed Cost

    10.829

    51.590

    11.756

    4.630

    3.522

    3.889

    4.415

    Cash Cost

    16.274

    68.270

    22.183

    9.968

    6.783

    8.209

    11.103

    Price*
    ~10%
    ~10%
    ~10%
    ~10%
    ~10%
    ~10%
    ~10%

_________________

 * With respect to price parameters, we assume a margin of 10% over total cost of goods sold, since
we do not conduct direct sales. With respect to commodity price, pricing dynamics for cement are a function of local supply and demand
and are not, like other commodities such as steel and iron ore, pegged to an index or to global commodity prices. In addition, cement
prices take into account the costs of cement plants, which may vary by plant and by company.

We will specify the currency with respect to the
pit optimization parameters in future filings.

*******

If you have any questions or require any additional information with respect
to the above, please do not hesitate to contact Tobias Stirnberg, CSN’s counsel, at +55 (11) 3927-7702.

Sincerely,

/s/ Antonio Marco Campos Rabello

___________________________________

Companhia Siderúrgica Nacional

By: Antonio Marco Campos Rabello

Title: Chief Financial and Investor Relations Officer

cc: Tobias Stirnberg

Milbank LLP

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