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 July 18, 2025

Marty Rendall
Chief Financial Officer
Electra Battery Materials Corp
133 Richmond Street West, Suite 602
Toronto, ON M5H 2L3

 Re: Electra Battery Materials Corp
 Form 20-F for the Fiscal Year ended December 31, 2024
 Filed April 24, 2025
 File No. 001-41356
Dear Marty Rendall:

 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 20-F for the Fiscal Year ended December 31, 2024
Controls and Procedures, page 96

1. We note you disclosure indicating that significant deficiencies had been
identified and
 resulted in the conclusions that your internal control over financial
reporting and
 disclosure controls and procedures were not effective as of December 31,
2024.

 However, in the Report of Management s Accountability on page 2 of
your financial
 statements, you have disclosure indicating that management identified
material
 weaknesses in your internal control over financial reporting and
disclosure controls
 and procedures related to the year ended December 31, 2024.

 Please revise as necessary to clarify whether material weaknesses or
significant
 deficiencies were identified. You may refer to the definitions of these
terms in Rule 1-
 02(a)(4) of Regulation S-X and AS 2201.A7 and .A11 for further
clarification.

 Please also expand your disclosures to describe any material weaknesses
in your
 internal control over financial reporting to comply with Item 15(b)(3)
of Form 20-F.
 July 18, 2025
Page 2

2. We note your disclosure under the heading Changes in Internal Control
over Financial
 Reporting on page 97, stating that while substantial progress has been
made in
 strengthening internal control over financial reporting during 2024,
management
 continues to assess and enhance internal controls of the company.

 Given the requirement to disclose any change in your internal control
over financial
 reporting that occurred during the period that materially affected, or
is reasonably
 likely to materially affect, your internal control over financial
reporting under Item
 15(d) of Form 20-F, please revise to describe the progress to which you
refer and to
 clarify the nature of its affect on your internal control over financial
reporting.

 With regard to your disclosure stating Electra has not yet implemented
"the full suite
 of systems, processes, and personnel typically found in more mature
organizations,"
 clarify the extent to which this refers to aspects of the controls and
procedures that
 your officers designed, as referenced in their certifications, and
describe your plans
 for implementation and dates for resolving the deficiencies or
weaknesses.

Exhibits

3. The certifications at Exhibits 12.1 and 12.2 do not include all of the
language required
 in paragraph 4, specifically as it relates to the officers acknowledging
responsibility
 for establishing and maintaining internal control over financial
reporting.

 Please amend the filing to include officer certifications that include
all of the language
 prescribed in paragraph 12 of the Instructions as to Exhibits of Form
20-F.

 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 Jenifer Gallagher at 202-551-3706 or John Cannarella at
202-551-3337
if you have questions regarding comments on the financial statements and
related matters.

 Sincerely,

 Division of
Corporation Finance
 Office of Energy &
Transportation
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