United States securities and exchange commission logo March 19, 2024 Marcelo Cunha Ribeiro Chief Financial Officer National Steel Company Av.Brigadeiro Faria Lima, 3400 - 20th floor Sao Paulo-SP, Brazil 04538-132 Re: National Steel Company Form 20-F for the Year Ended December 31, 2022 Response dated March 6, 2024 File No. 001-14732 Dear Marcelo Cunha Ribeiro: We have reviewed your March 6, 2024 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 February 28, 2024 letter. Form 20-F for the Fiscal year Ended December 31, 2022 Item 4. Information on the Company General, page 17 1. We note that you have included a draft of your material property resource and reserve tables. Please ensure resources are reported exclusive of mineral reserves and that your revised disclosure includes the point of reference (for example in-situ, mill feed, or saleable product), the cut-off grade, and the metallurgical recovery factor as required by Item 1304(d)(1) of Regulation S-K for material properties. Marcelo Cunha Ribeiro FirstName LastNameMarcelo Cunha Ribeiro National Steel Company Comapany March NameNational Steel Company 19, 2024 March2 19, 2024 Page 2 Page FirstName LastName 2. We note that you have included a draft of your non-material property resource and reserve tables. Please ensure resources are reported exclusive of mineral reserves and that your revised disclosure includes the point of reference (for example in-situ, mill feed, or saleable product) and the commodity price, as required by Item 1303(b)(3) of Regulation S-K for non-material properties. 3. Please file your amended Form 20-F for the fiscal year ended December 31, 2022 and the revised technical report summary that includes revisions that address all staff comments. Please ensure all information required under Item 1304 of Regulation S-K is included in the amendment for your material mining properties. If you have any questions regarding mining comments, please contact John Coleman at 202-551-3610 or Craig Arakawa at 202-551-3650. Please contact Melissa Gilmore at 202-551- 3777 or Kevin Woody at 202-551-3629 if you have any other questions. Sincerely, Division of Corporation Finance Office of Manufacturing