United States securities and exchange commission logo

                              October 4, 2023

       Beatriz Garc  a-Cos
       Chief Financial Officer and Principal Accounting Officer
       Ferroglobe PLC
       13 Chesterfield Street
       London W1J 5JN, United Kingdom

                                                        Re: Ferroglobe PLC
                                                            Form 20-F for the
Fiscal Year Ended December 31, 2022
                                                            Response dated
September 21, 2023
                                                            File No. 001-37668

       Dear Beatriz Garc  a-Cos:

              We have reviewed your September 21, 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 August 24,
       2023 letter.

       Form 20-F for the Fiscal Year Ended December 31, 2022

       Key Information, page 5

   1.                                                   We note your response
to prior comment 2 that you did not experience any material
                                                        indirect consequences
of climate-related regulation or business trends. However, you also
                                                        state you are actively
developing carbon reduction targets and initiatives and are aiming to
                                                        meet the expectations
of your stakeholders that are beginning to demand products with a
                                                        lower carbon footprint.
Please include a discussion explaining in greater detail your
                                                        analysis and how you
concluded on materiality for each of the items noted below:
                                                            decreased demand
for goods or products that produce significant greenhouse gas
                                                             emissions or are
related to carbon-based energy sources, including the basis for your
                                                             statement that you
do not anticipate a significant change in the industry's technology
                                                             for production of
the products you produce;
 Beatriz Garc  a-Cos
Ferroglobe LastNameBeatriz Garc  a-Cos
October    NameFerroglobe PLC
        4, 2023
Page 2 4, 2023 Page 2
FirstName LastName
                increased demand for goods that result in lower emissions than
competing products;
                increased competition to develop innovative new products that
result in lower

         Your response also indicates that your risk factor disclosure on page
10 addresses
         reputation risks relating to your operations that produce material
greenhouse gas
         emissions. However, such discussion appears to focus on the impact to
your reputation
         that may result from a regulatory violation. Please tell us what
consideration you have
         given to including disclosure regarding any potential reputation risks
from your operations
         that produce greenhouse gas emissions, including from stakeholders,
customers and
2.       We note your response to prior comment 3. Please further address the
             Your response acknowledges that there is always the potential for
natural disasters
            and extreme weather conditions to occur as a result of global
climate change. Your
            response also indicates that you have experienced non-material
direct impacts as a
            result of weather-related incidents in recent years. Please explain
how you assessed
            the materiality of weather-related incidents and quantify all
weather-related damages
            to your property and operations.
             Your 2021 Global ESG report reflects that your water consumption
totaled 27.7M
            cubic meters and is made up of 43% surface water, 37% from third
parties and 20%
            ground water. Please tell us how you considered including
disclosure regarding the
            impact of water availability and quality to your operations and
             Please revise your disclosure to address how you could be impacted
if severe weather
            impacts your customers or suppliers. In this regard, we note your
response reflects
            Colombia has experienced heavy rains and South Africa and the
United States have
            suffered from flooding, and your Form 20-F reflects that 59% of
your third-party coal
            purchases came from a single mine in Colombia and nearly all the
manganese ore
            you purchase comes from suppliers in South Africa and Gabon.
             Your response states that your property insurance underwriting
rate has consistently
            measured between 1.4 and 1.5. Please provide us with information
quantifying the
            cost of property insurance for each of the periods for which
financial statements are
            presented in your Form 20-F and whether you expect any future
period changes to the
            cost of insurance.

       Please contact Michael Purcell at 202-551-5351 or Karina Dorin at
202-551-3763 with
any questions.


                                                              Division of
Corporation Finance
 Beatriz Garc  a-Cos
Ferroglobe PLC
October    LastNameBeatriz Garc  a-Cos
        4, 2023
Page 3
Comapany   NameFerroglobe PLC
October 4, 2023 Page 3                  Office of Energy & Transportation
FirstName LastName