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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.
 Jack Guo
FirstName
ConstelliumLastNameJack Guo
            SE
Comapany18,
February   NameConstellium
             2024          SE
February
Page 2 18, 2024 Page 2
FirstName LastName
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