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 June 17, 2025

Nathan R. Bennett
Chief Financial Officer
Energy Fuels Inc.
225 Union Blvd., Suite 600
Lakewood, Colorado 80228

 Re: Energy Fuels Inc.
 Form 10-K for the Fiscal Year ended December 31, 2024
 Filed February 26, 2025
 File No. 001-36204
Dear Nathan R. Bennett:

 We have reviewed your filing and have the following comments.

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.

Form 10-K for the Fiscal Year ended December 31, 2024
Description of Properties, page 74

1. We note that you have included tabulations of mineral resources and
 reserves on pages 80, 83, 154, 155, 163, and 164, pertaining to the
Toliara and Donald
 projects, which you indicate are based on JORC guidelines and do not
conform to the
 U.S. requirements in Item 1300 of Regulation S-K.

 However, the mineral property disclosures that you provide in the annual
report must
 conform to Subpart 1300 of Regulation S-K, and disclosures of mineral
resources and
 reserves must be supported by a technical report summary that conforms
to the
 requirements in Item 601(b)(96) of Regulation S-K.

 Please revise as necessary to adhere to these requirements; you may
refer to Items
 1301(b) and 1302(a)(1) and (b)(1) and (b)(2)(i) of Regulation S-K if you
require
 further clarification or guidance pertaining to these requirements.
 June 17, 2025
Page 2

Management's Discussion and Analysis
Operations Update and Outlook for 2025, page 187

2. We note your disclosure on page 20 regarding the Kwale mining operation
acquired
 along with Base Resources Limited during the fourth quarter of 2024,
explaining that
 mining concluded as the ore reserves were depleted by the end of the
year,
 while specifying the related quantities of ilmenite, rutile, and zircon
that were sold
 and which generated $39.87 million in revenues during the fourth quarter
(which
 exceeded total revenues for first nine months of the year, prior to the
acquisition). You
 also indicate that processing concluded in January 2025, and that all
remaining
 product stockpiles are expected to be sold during the first quarter of
2025.

 However, we see that you have comparatively limited disclosure in the
last paragraph
 on page 188, in terms of revenue details, and do not mention the
non-recurring nature
 of these revenues in your discussion and analysis of consolidated or
segment revenues
 on pages 196 and 200. We also see that you have similarly limited your
discussion
 and analysis of revenues in the first quater interim report, and in
disclosures pertaining
 to the heavy mineral sands segment on page 42, under the heading Sales
Update and
 Outlook for 2025, where you mention the quantities of minerals sold and
revenues,
 which represented about 92% of the total for the period, though also
without
 providing commentary on the outlook or non-recurring nature of this
activity.

 Item 303(a) and (b) of Regulation S-K require that you focus on matters
that
 are "reasonably likely to cause reported financial information not to be
necessarily
 indicative of future operating results or of future financial
condition." For example,
 this would include providing "descriptions and amounts of matters that
have had a
 material impact on reported operations, as well as matters that are
reasonably
 likely...to have a material impact on future operations," which would
generally
 encompass the cessation of a material revenue generating activity. When
financial
 statements reflect material changes in one or more line items, and when
there are
 material offsetting changes within a line item, these also require that
you "describe the
 underlying reasons for such changes in quantitative and qualitative
terms."

 Please modify your discussion and analysis of revenues as neecssary to
adhere to
 these requirements; the extent to which revenues are derived from
recurring and non-
 recurring sources, along with the reasons for the irregularity that has
been
 characteristic of your revenue sources, should be apparent from these
disclosures.

Known Trends or Uncertainties, page 195

3. We note your disclosure explaining that you are not aware of any trends
or
 uncertainties that have had, or that are reasonably likely to have, a
material impact on
 revenues or income except for several matters, which appear to be
generally external
 to the company, including activity in uranium markets, U.S. government
laws and
 programs, and mineral price volatility, though also including an
uncertainty about
 initiatives the company may undertake which may or may not be
successful.
 June 17, 2025
Page 3

 Given the significance of the temporary financial activity associated
with your recent
 acquisition, in relation to that of your uranium mining operations, the
disclosures that
 you provide under this heading do not appear to be sufficiently
responsive to Item
 303(b)(2)(i) and (ii) of Regulation S-K, as to the requirements to
describe unusual or
 infrequent events or transactions, and significant economic changes that
materially
 affected the amount of reported income from continuing operations,
including known
 trends or uncertainties that have had, or that are reasonably likely to
have, a material
 impact on revenues or income from continuing operations.

 Please expand your disclosures to provide appropriate quantification and
clarification
 in this regard; also refer to Sections III.B.3 and 4 of the Commission
Guidance
 Regarding Management's Discussion and Analysis of Financial Condition
and Results
 of Operations (Release Nos. 33-8350; 34-48960; FR-72), pertaining to the
discussion
 and analysis of known trends, demands, commitments, events and
uncertainties,
 which relates to disclosures required under Item 303 of Regulation S-K,
regarding the
 objective of providing information about the quality and potential
variability of
 earnings and cash flow, along with the underlying reasons, implications,
 interrelationships, and relative significance of associated matters, so
that readers can
 ascertain the likelihood that past performance is indicative of future
performance.

 You may view the aforementioend guidance at the following address:

https://www.sec.gov/rules-regulations/2003/12/commission-guidance-regarding-
 managements-discussion-analysis-financial-condition-results-operations

 We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence
of action by the staff.

 Please contact John Coleman at 202-551-3610, Yolanda Guobadia at
202-551-3562,
or Karl Hiller at 202-551-3686 if you have questions regarding comments.

 Sincerely,

 Division of
Corporation Finance
 Office of Energy &
Transportation
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