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 Electra Battery Materials Corporation

 133 Richmond Street West, Suite 602

 Toronto, ON M5H 2L3

 Canada

 https://www.electrabmc.com/

 July 25, 2025

 VIA EDGAR

 U.S. Securities and Exchange Commission

 100 F. Street, N.E.

 Washington, D.C. 20549

 Attention: Jenifer Gallagher and John Cannarella

 Re:

 Electra Battery Materials Corporation
 Form 20-F for the Fiscal Year Ended December 31, 2024
 Filed April 24, 2025
 File No. 001-41356

 Ladies and Gentlemen:

 I am submitting this letter on behalf of Electra Battery Materials Corporation
(the " Company "), in response to the written comments of the staff (the " Staff ") of the U.S. Securities
and Exchange Commission (the " SEC "), contained in the Staff's letter, dated July 18, 2025 (the " Comment
Letter "), in connection with the Company's Form 20-F for the Fiscal Year Ended December 31, 2024, filed with the SEC on
April 24, 2025 (the " Form 20-F ").

 For your convenience, the Company's responses are set forth below,
with the headings and numbered items of this letter corresponding to the headings and numbered items contained in the Comment Letter.
Each of the comments from the Comment Letter is restated in bold and italics prior to the Company's response.

 Form 20-F for the Fiscal Year Ended December 31, 2024

Controls and Procedures, page 96

 1. We note your 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.

 Securities and Exchange Commission July 25, 2025 Page 2

 The Company has revised the Item 15 disclosure regarding Controls
and Procedures under the subheadings "Disclosure Controls and Procedures" and "Management Report on Internal Control
Over Financial Reporting" on page 96 of the Form 20-F to clarify that the Company identified material weaknesses in the internal
controls over financial reporting and disclosure controls and procedures over the course of the first three quarters of the fiscal year
ended December 31, 2024, but that improvements to its internal controls over financial reporting and disclosure controls and procedures
were made by the Company in each of the third and fourth quarters of the fiscal year ended December 31, 2024, such that the previously
identified material weaknesses had become significant deficiencies by the end of the fiscal year on December 31, 2024. The Company has
also made corresponding changes to the Report of Management's Accountability contained on page 2 of its annual consolidated financial
statement for the fiscal years ended December 31, 2024, 2023 and 2022 included in the Form 20-F.

 The Company has also added disclosure in Item 15 of the Form
20-F describing the material weaknesses in the internal controls over financial reporting and disclosure controls and procedures, which
include the following:

 (i) An ineffective control environment resulting from the combination of an insufficient number of trained
financial reporting and accounting personnel with the appropriate skills and knowledge regarding the design, implementation, and operation
of internal control over financial reporting.

 (ii) Management had not designed or implemented a control monitoring process necessary to identify control
weaknesses and remediations in a timely manner necessary to ensure the reliability of its internal control over financial reporting.

 (iii) Control deficiencies in procurement and payment resulting from a lack of formal processes and inconsistent
receiving processes at the Company's refinery project.

 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 effect 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.

 The Company has revised the Item 15 disclosure regarding Controls
and Procedures under the subheading "Changes in Internal Control over Financial Reporting" to describe the material improvements
that were made over the course of each of the third and fourth quarters of the fiscal year ended December 31, 2024 to the internal control
over financial reporting, as well to describe the additional improvements that the Company intends to take when its primary assets are
brought out of care and maintenance mode when such additional improvements are warranted. The Company is proposing to add the following
disclosure under the subheading "Changes in Internal Control over Financial Reporting":

 "The Company's CEO and CFO identified the following
areas where material improvements were made during the fourth quarter of fiscal 2024.

 · Control Environment

 o The Company increased the number of trained financial reporting and accounting personnel with the appropriate
skills and knowledge regarding the design, implementation, and operation of internal controls over financing reporting.

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 Securities and Exchange Commission July 25, 2025 Page 3

 · Control Monitoring Process

 o The Company implemented a control monitoring process to identify weaknesses in its internal control over
financial reporting.

 · Procurement, Payment and Receiving Processes

 o The Company improved reporting and receiving processes to ensure adherence to the Company's policies
at the Company's refinery project.

 The Company's primary assets, including its hydrometallurgical
refinery in Ontario, Canada and its cobalt exploration properties in Idaho, USA, are currently on care and maintenance. One or both of
these assets are expected to become more active during fiscal 2025 and 2026, at which time, the Company intends to further enhance and
improve its internal control over financial reporting appropriately for such additional activities. Specific areas of focus are expected
to be: (i) the control environment, including IT infrastructure and processes, and internal audit function; (ii) the control monitoring
process; (iii) the payroll process; (iv) the property, plant and equipment process; and (v) the procurement, payment and receiving processes."

 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.

 The Company has amended the Form 20-F 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 thank you for your prompt attention to this letter responding
to the Staff's Comment Letter and look forward to hearing from you at your earliest convenience. Please direct any questions concerning
this filing to the undersigned at (226) 979- 6699 or mrendall@electrabmc.com.

 Sincerely,

 /s/ Marty Rendall

 Chief Financial Officer

 Electra
Battery Materials Corp

 cc:

 Via Email
 Thomas M. Rose, Troutman Pepper Locke LLP
 Shona C. Smith, Troutman Pepper Locke LLP

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