July 27, 2018

Marcelo Ribeiro
Chief Financial and Investor Relations Officer
NATIONAL STEEL CO
Av.Brigadeiro Faria Lima, 3400 - 20th floor
04538-132, Sao Paulo-SP, Brazil

        Re: NATIONAL STEEL CO
            Form 20-F for the year ended December 31, 2017
            Filed on May 1, 2018
            File No. 001-14732

Dear Mr. Ribeiro:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments. In some of our comments, we may
ask you to
provide us with information so we may better understand your disclosure.

       Please respond to these comments 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 our
comments apply to your facts and circumstances, please tell us why in your
response.

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

Form 20-F for the year ended December 31, 2017

8.a) Direct equity interests in subsidiaries, joint ventures, joint operations,
associates and other
investments, page FS-29

1.     We note your tabular disclosure for the various investments accounted
for under the
       equity method and the various joint ventures and joint operations that
the company is a
       part of. As it relates to your investment in Transnordestina Logistica
S.A., please clarify
       what the fair value allocated to TLSA in loss of control is intended to
represent. In that
       regard, please tell us and further expand your disclosures to clarify
the facts and
       circumstances that may have resulted in the loss of control of your TLSA
investment and
       the related accounting treatment and authoritative literature you relied
on.
8.d) Joint ventures and joint operations financial information, page FS-33
 Marcelo Ribeiro
NATIONAL STEEL CO
July 27, 2018
Page 2
2.       Please further tell us and expand your disclosures to discuss the
facts and circumstances
         that resulted in the determination an impairment trigger was present
in 2016 that resulted
         in the evaluation of TLSA's own long lived assets. In that regard,
please clarify whether,
         the R$387,989 that was recorded as other operating expenses
represented the write down
         of your investment in TLSA or whether that was the company's
proportional amount of
         any impairment loss that was recognized by TLSA. Please tell us how
you applied the
         guidance in paragraphs 40-42 of IAS 28 given that it appears you are
accounting for your
         investment in TLSA as an equity method investment based on your
disclosure on page
         FS-10.
23.Other Operatinig Income (Expenses), page FS-72

3.       We note your tabular disclosure detailing the various line items
impacting your other
         operating income and expenses for the periods presented. Please
further expand your
         disclosures to highlight the facts and circumstances that led to the
R$755,151 monetary
         adjustment related to the Eletrobras Compulsory loan. In that regard,
please clarify
         the nature of the arrangement with Eletrobras and the resulting
negotiation and/or conflict
         that resulted in a favorable judicial decision. In your response,
please also address how
         you are accounting for the arrangement with Eletrobras.
       In closing, 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.

       You may contact Ameen Hamady, at 202-551-3891 or in his absence, Terence
O'Brien at 202-551-3355 with any questions.


FirstName LastNameMarcelo Ribeiro
                                                              Division of
Corporation Finance
Comapany NameNATIONAL STEEL CO
                                                              Office of
Manufacturing and
July 27, 2018 Page 2                                          Construction
FirstName LastName