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February 18, 2024
Jack Guo
Chief Financial Officer
Constellium SE
Washington Plaza
40-44 rue Washington
75008 Paris
France
Re:Constellium SE
Form 20-F for the fiscal year ended December 31, 2022
Filed March 14, 2023
Form 6-K furnished July 26, 2023
File No. 001-35931
Dear Jack Guo:
            We have reviewed your December 20, 2023 response to our comment letter 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. Unless
we note otherwise, any references to prior comments are to comments in our November 21,
2023 letter.
Form 20-F for the Fiscal Year Ended December 31, 2022
Operating and Financial Review and Prospects
Segment Adjusted EBITDA, page 46
1.We note your response to prior comment 1. We continue to believe that the adjustment for
metal price lag to arrive at Adjusted EBITDA, or any other non-GAAP measure, is
inconsistent with the guidance in Question 100.04 of the Staff's Compliance and
Disclosure Interpretations on Non-GAAP Financial Measures. Please remove this
adjustment from all non-GAAP measures in future filings.

 FirstName LastNameJack Guo
 Comapany NameConstellium SE
 February 18, 2024 Page 2
 FirstName LastName
Jack Guo
Constellium SE
February 18, 2024
Page 2
Form 6-K furnished July 26, 2023
Exhibit 99.1, page 14
2.Your response to prior comment 2 states that you consider the non-GAAP measure Value-
Added Revenue (“VAR”) as a measure of profitability, which is calculated by deducting
certain costs from revenues. We also note from your response that the hedged cost of
alloyed metal adjustment does not include all cost of sales items related to the revenue
presented in the measure. As a profitability measure, excluding cost of sales items related
to the recognized revenue could be misleading considering the measure would exclude
normal, recurring, cash operating expenses necessary and directly related to the revenue
recognized. Please provide the following information related to the adjustments included
in this non-GAAP measure:

•Provide revenue disaggregated for the amount related to contracts that allow you to
pass-through aluminum and alloyed metal prices to customers and those that are
based on fixed pricing.

•For contracts that allow you to pass-through aluminum and alloyed metal prices,
explain whether it is within the contract terms that such costs are pass-throughs to the
customers, whether the arrangements are considered cost-plus fixed fee or cost
reimbursable plus fee types of contracts, and how the cost of the aluminum and
alloyed metals are included on invoices or billings to the customer.

•Explain how the cost of aluminum and cost of alloying metals amounts are
determined for the “Hedged cost of alloyed metal” adjustment. For example, tell us
whether it represents the actual cost within your cost of sales line item that is based
on the weighted average cost of metal under IFRS or another calculation, such as the
average all-in aluminum price based on the location where metal was purchased,
multiplied by the metal sold in the period.
            Please contact Eiko Yaoita Pyles at 202-551-3587 or Andrew Blume at 202-551-3254 if
you have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Manufacturing