gss.civilservice.gov.uk · web viewnace rev. 2 review. outcome review task force consultation....

NACE Rev. 2 Review

Outcome Review Task Force consultationDivision 26-39

Proposal 58PROPOSAL: 1. Code: 26 - Manufacture of computer, electronic and optical products

Proposal: Future challenges rely to a large extent on the use of sensors, e.g. in traffic or health care. Industrial association (AMA) is estimating that the number of sensors in use worldwide doubles at least every five years, and the global demand for them will surpass one trillion sensors in the foreseeable future. Proposal of change: More explicit consideration of both, sensing elements and sensing equipment. Submitted by: Germany Please provide your comment on this proposal:

Austria Austria: Production of sensors is classified in 26.11, 26.51, 27.33. It is right, that their importance is increasing. Austria proposes to identify them better in CPA and PRODCOM, because a new class for production of sensors. Would have the content of three existing classes.

Croatia We need more information on this and if possible, some concrete proposals, but generally, we support the proposal. Explanatory notes of division 26 can be improved.

Denmark Are new codes necessary? Can't it be solved by adding to the explanatory notes?

Finland Manufacture of sensing ELEMENTS to be added as an explanatory note to 26.11 Manufacture of electronic components. A suggestion for the wording: "This class includes: […] - manufacture of sensors responding to a physical stimulus (such as heat, light, sound, pressure, magnetism, or a particular motion) and transmitting a resulting impulse (as for measurement or operating a control)". [Source for the definition https://www.merriam-webster.com/dictionary/sensor, referred on 13 Aug 2019.]

We doubt whether one and the same class for manufacture of all sensing EQUIPMENT could serve any meaningful economic/social analysis. Technology, raw materials and intention of use differ all to a great extent. As examples of sensing EQUIPMENT are heart rate monitors, trail cameras, fire alarms/smoke detectors, … On the other hand, manufacture of sensing EQUIPMENT is largely included in Class 26.51.

Finland suggests that Eurostat compiles data on the size of the group for considerations of splitting the class in one way or another.

Please note the difference between sensing ELEMENTS and sensing EQUIPMENT. The element can be used as a component to multifarious

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equipment.

On the side we made two observations which we will include in the large consultation (due 30 Sept 2019):

1. An exclusion in Class 26.11: "This class excludes: […] - manufacture of similar devices for electrical applications, see division 27". Is the difference between "electronic" and "electrical" clear-cut? If a component or a device is multi-purpose in sense that it may be used for both electronic and electrical application how to justify the classification of such component according to its end-use? We suggest either

a. re-arranging the divisions 26 and 27 to classify manufacture of all similar components and devices to one and the same class, or

b. clarifying the explanatory notes for inclusions and exclusions to avoid possibility for ambiguous interpretations.

2. Is there still a need for Group 26.8 Manufacture of magnetic and optical media? Eurostat could compile the data on the size of the group on EU level.

Finland suggests applying the top-down (general) approach to Divisions 26 and 27 to revise their structure afresh.

France

Sensing elements :

A sensor is a device that detects and responds to some type of input from the physical environment. The specific input could be light, heat, motion, moisture, pressure, or any one of a great number of other environmental phenomena. The output is generally a signal that is converted to human-readable display at the sensor location or transmitted electronically over a network for reading or further processing.

We can find today a lot of different sensors :

- In a mercury-based glass thermometer, the input is temperature. The liquid contained expands and contracts in response, causing the level to be higher or lower on the marked gauge, which is human-readable.

- An oxygen sensor in a car's emission control system detects the gasoline/oxygen ratio, usually through a chemical reaction that generates a voltage. A computer in the engine reads the voltage and, if the mixture is not optimal, readjusts the balance.

- Motion sensors in various systems including home security lights, automatic doors and bathroom fixtures typically send out some type of energy, such as microwaves, ultrasonic waves or light beams and detect when the flow of energy is interrupted by something entering its path.

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- A photosensor detects the presence of visible light, infrared transmission (IR), and/or ultraviolet (UV) energy.

These sensors are also used in health care :

- Some firms has developed ingestible sensors : it is a small wearable sensor patch, an application on a mobile device and a provider portal. Once activated, it unlocks insight into patient health patterns and medication treatment effectiveness (and patients can easily monitor their medication-taking patterns on their mobile device).

- A sensor can be placed under a bed mattress, it is used by hospitals, nursing facilities and rehabilitation organizations to assist with early detection and help healthcare teams intervene earlier and prevent unnoticed and potentially harmful events. The solution utilizes artificial intelligence and big data analysis to accurately and continuously monitor cardiac and respiratory cycles, as well as patient movement, without ever touching the patient. By capturing patient data continuously, the solution enables health teams to accurately track trends and changes in patient status, including baseline deviations that may otherwise go undetected using traditional methods.

Etc…

______________________________________________________________________________________

France proposal : We would classify the manufacture of sensing elements in 26.11 (and we should add a new CPA for these products).

Are there other types of sensors that could not be classified in 26.11 ?

Another solution (We are not in favour of this position) would have been to classify the manufacture of the sensor with the manufacture of the equipment in which it is integrated. ______________________________________________________________________________________

Sensing equipment :

______________________________________________________________________________________

France proposal : There is not a unique class to classify the manufacture of sensing equipment.

Some of them are classified in « 26.51 Manufacture of instruments and appliances for measuring, testing and navigation » (e.g. thermometers, ) others in « 26.30 Communication equipment » (e.g. manufacture of burglar and fire alarm systems, sending signals to a control station), etc.

We can add new notes to NACE about these sensing equipment, but we don’t think a new class is the solution.

________________________________________________________________________________________

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France already sent

Germany Adding "sensing equipment" to the explanatory notes of division 26 and group 26.5 and "manufacture of sensing elements" to the explicit inclusions of class 26.11.

Greece What means more explicit consideration? new class or more explanatory notes?. we are opposite to the creation of a new class because we believe that such a detailed break down is unnecessary at the activity classification but we agree with more explanatory notes concerning sensing elements and sensing equipment.

Hungary Hungary: We agree with the proposal.

We classify the sensing elements is in the 26.11 Manufacture of electronic components and the sensing equipment is in the 26.51 Manufacture of instruments and appliances for measuring, testing and navigation.

Italy The term “sensor” is not even cited in the NACE classification; when the NACE Rev. 2 was developed such term was indeed too generic. With regards to the proposal by Germany, it is important to correctly understand the meaning.

1) Does the wording “sensing elements” mean specialised parts to be used on equipment and machineries? Is there a relevant number of units which especially produce such parts?

2) Does the term “sensing equipment” refer to monitoring instruments? And there can really be such kind of equipment without sensors?

What’s more the choice of division 26 is doubtful.

In Italy, for the SBR experts it is really difficult to distinguish between electronic vs electric components because nowadays most of equipment and households (classified in division 27) have electronic parts.

Lithuania We agree with this proposal. Explanatory notes should be supplemented about the manufacture of sensors. A sensor is a device, module, or subsystem whose purpose is to detect events or changes in its environment and send the information to other electronics, frequently a computer processor. A sensor is always used with other electronics. Applications include manufacturing and machinery, airplanes and aerospace, cars, medicine, robotics and many other aspects of our day-to-day life. In Prodcom there is no code for sensors.

Malta no comment

Netherlands This might be useful although if there is an overlap with radar and motion detector etc. equipment (26.5).

Poland We support Germany’s proposal. We suggest adding the sensors in the explanatory notes to the Division 26.

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It should be borne in mind that the sensor is on the device, module or subsystem, the purpose of which is to detect events or changes in the unit / electronic device, often a computer processor. The sensor is always used with other electronic devices.

Slovenia We suggest that the sensors are explicitly written in the CPA Ver. 2.1, if not already in the NACE classification.

Sweden Isn't this included in 26.51? Mostly all of this class should in practice include manufacturing of different sensors, detectors etc.

Switzerland This problem also includes sensors for domestic appliances (blinds, safety elements, robotic vacuum cleaners, automotive sensors) and domestic appliances (roomba).

We can improve the explanatory notes.

United Kingdom Agree overall

To help inform discussion: NAICS 2017 gives the following (Correlation to NACE Rev 2 shown in brackets)

334413 (26.11) Infrared sensors, solid-state, manufacturing

334511 (26.51) Cabin environment indicators, transmitters, and sensors manufacturing

334511 (26.51) Flight and navigation sensors, transmitters, and displays manufacturing

334512 (26.51) Temperature sensors for motor windings manufacturing

334513 (26.51) Primary process temperature sensors manufacturing

334516 (26.51) Thermal conductivity instruments and sensors manufacturing

RECOMMENDATION:No new class for sensing elements nor sensing equipment. Manufacture of sensing elements to be added in the explanatory notes of 26.11. Create a CPA sub-class for sensing elements.Sensing equipment are mainly included in 26.51, but they can also be classified on 26.11 26.30, 27.33. Explanatory notes of these classes should include them.


Proposal: There are doubts that the divergent treatment of computer cables in CN respectively of their manufacturing in ISIC Rev. 4 is justified with respect to the character of the goods and the technology of production. Proposal of change: Adjust the borderline between divisions 26 and 27 with regard to computer cables consistently to product classifications. Submitted

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by: Germany Please provide your comment on this proposal:

Austria Austria totally agrees with Germany to move the production of computer cables from 26.11 to 27.90. We should move printer cables, monitor cables and USB cables, too.

Croatia We agree with the proposal.

Denmark we agree. Should be solved through clarification of notes

Finland With the focus on NACE only, manufacture of fibre optic cables should logically be in Division 26, not 27. This is the position of our ICT expert from enterprise statistics. See for example the explanatory note of Class 26.11 "This class also includes: - manufacture of printer cables, monitor cables, USB cables, connectors etc." Currently such manufacture is included in Class 27.31 Manufacture of fibre optic cables. However, Group 27.3 carries the (misleading) title "Manufacture of wiring and wiring devices".

PRODCOM states that codes starting with 27311… cover fibre optic cables whereas computer cables are part of PRODCOM code 26204000 (HS 8471 and CN 84733020, 84733080, 84735020, 84735080). From PRODCOM's viewpoint the current NACE classes are correct.

For National Accounts manufacture of "big cables" is located in Division 27 and of "small cables" in Division 26, a rule of thumb which may not really be in line with the NACE spirit.

Manufacture of all mentioned cables is small in size in Finland. Therefore Finland has no strong opinion on the matter. However, for reasons of logic in NACE, Finland is in favour of moving manufacture of fibre optic cable from class 27.31 to 26.11.


France Indeed, these question has already been raised on Circa forum

(https://circabc.europa.eu/ui/group/be60258d-6db0-4d3c-8bf9-79f34f119da1/forum/topic/84acbf20-6a95-4eab-a1aa-fb74ea88045e)

ISIC and NACE are consistent : manufacture of printer cables, monitor cables, USB cables, connectors are respectively classified in « 2610 Manufacture of electronic components and boards » and « 26.11 Manufacture of electronic components ».

But in CPA 26.11, there is no heading or product that corresponds to the

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manufacture of printer cables.

It seems logical that the manufacture of printer cables should be classified in 26 Manufacture of computer, electronic and optical products. Indeed, these products transmit information and not electricity. The manufacture of cables classified in 27 should remain either cables without connectors (27.3) or cables which transmits electricity (27.90).

The problem seems to come from the CN-CPA correspondence table (and Prodcom), the cables described in 8544 are either linked to « 27.90 Other electrical equipment » or « 27.32 Other electronic and electric wires and cables ». Maybe a link is missing between 8544 and a new CPA class in 26.11 ?

_____________________________________________________________________________________

France proposal :

- create a CPA in 26.11.xx for the manufacture of computer cables.

_____________________________________________________________________________________

Information :

ISIC 2610

2610 Manufacture of electronic components and boards

This class also includes:

——manufacture of printer cables, monitor cables, USB cables, connectors etc.

NACE 26.11

26.11 Manufacture of electronic components


- manufacture of printer cables, monitor cables, USB cables, connectors etc.

France already sent

Germany Bundling of "manufacture of printer cables, monitor cables, USB cables, connectors etc." from class 26.11 and also of "manufacture of extension

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cords made from purchased insulated wire" in one class together with "Manufacture of other electronic and electric wires and cables" (27.32).

Greece If we decide to classify the computer cables as a product, we believe that they should be classified in division 27 like all cables.


NACE 26.11 Manufacture of electronic components


- manufacture of printer cables, monitor cables, USB cables, connectors etc.

PC and printer cables that can be connected to the electrical network:

NACE 27.32 Manufacture of other electronic and electric wires and cables

This class excludes: - manufacture (drawing) of wire, see 24.34, 24.41, 24.42, 24.43, 24.44, 24.45 - manufacture of computer cables, printer cables, USB cables and similar cable sets or assemblies, see 26.11

Italy More in general, according to Italy there is the need to adjust the borderline between division 26 and 27 (see Italian comment to proposal 1). The proposal made by Germany can be shared once we have clarified the boundaries between the two divisions, the two production processes and technologies of production.

Lithuania We agree on this proposal. The explanatory notes need to be supplemented with explicit naming of computer cables.

Malta no comment

Netherlands Agree. A possible solution would be to include this product under the exclusion part of 26.

Poland We support Germany's proposals. Cables for computer equipment:

NACE 26.11 – The notation "This class also includes" should be deleted from the explanatory notes.

CPA 27.90.44 (new grouping in CPA 2.1) is linked to CN 8544 42 Electric conductors, for voltages ≤ 1000 V, insulated, fitted with connectors n.e.c.

Therefore, we have taken the position that cables for printers, monitors, USB, connectors should be classified in NACE 27.90 and the relevant notation in the explanatory notes should be included in the field of this class.

Slovenia We agree with the clarification of the boundary between sections 26 and 27.

Sweden Agree, it seems that different kind of cables/wires is included in both 26 and 27. If there is an inconsistency we are in favour of the proposal.

Switzerland There is also confusion with the various products that were electrical, but are

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becoming increasingly electronic, such as headphones. It's necessary to define guidelines to classify this types of activities.

We have to improve the explanatory notes. But a popularization of the domain is necessary. The descriptions used are too technical.

United Kingdom This has not been raised as a concern by UK users, however further clarity would be welcomed

PL: We reiterate our proposal that cables for printers, monitors, USB should be classified in NACE 27.90 and the relevant entry in the explanatory notes should be introduced in this class. In addition, insulated cables for voltage ≤1000 V, fitted with connectors, should be removed from NACE 27.32.

FR: Among the 3 proposals, our preference is:

1. Separate cables for transmitting electricity from cables transmitting information (in consistency with ISIC 2610)

2. Have all cables together (26 or 27) ==> ISIC should be amended too (cf.2610)3. big cables/small cables ==> we don't support this proposal at all : it's not a clear

criteria. We don't think it's operational or even consistent with criteria that explain the limits between divisions 26 and 27

AT: We are against a split in big/small cables, the difference is not clear, The production process is different between cables for electricity and cables for transmitting information, so they should be seperated.

HU: Regardless of size, cables should only be disassembled according to whether they transmit electricity or information. DK: it can make sense to split cables for information and electricity

RECOMMENDATION:All cables should be together. Where to classify them would depend on the result of the discussions on reorganization of division 26 and 27 as the boundary between electronic and electric is becoming blur.


Proposal: This activity is developing fast, so it is more and more difficult to classify the newest computer products and consumer electronics into the appropriate activity class of NACE. Proposal: to include examples in the explanatory notes of NACE 26 (set-top box, blue-ray players, Apple TV, Xbox, drone, VR headset, JBL, etc.). Submitted by: Hungary Please provide your comment on this proposal:

Austria Austria is against this proposal, because to mention only some products with

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the name of the enterprise, which produces it, is not good. Hungary can create an alphabetical index to include this products (set-top box, blue-ray players, Xbox,...).

Croatia We agree with the proposal, explanatory notes need to be improved and supplemented by examples mentioned above.

Denmark Adjust the notes with a few examples, but we shouldn't include brand names in the notes, since brand names can change.

Finland Manufacture of "smart products" (especially in current Classes 26.30 Communication equipment and 26.40 Consumer electronics) will most probably undergo a rapid growth within the period of validity of the next NACE. The best solution may not be to add all product names currently existing to explanatory notes. The list of such products risks to become outdated fast, and there will be a need for constant rulings to such list.

Many classes under Division 26 have fused to a great extent, especially 26.30 and 26.40. Manufacture of (multipurpose) consumer electronics is often hard to distinguish from manufacture of (multipurpose) communication equipment. Moreover, the borderline between household and professional use has blurred.

Finland suggests to thoroughly scrutinize the explanatory notes of both 26.30 and 26.40. Brand names (Apple, Xbox, JBL, …) and specific technologies (GPS, blue-ray, …) should be avoided. For example, instead of blue-ray players an inclusion of "digital devices that produce digital sound and/or images, such as blue-ray (2019)". GPS is to be replaced by "global navigation satellite system GNNS". The term covers Galileo (Europe), GPS (U.S.), GLONASS (Russia), IRNSS (India), QZSS (Japan) and other.

Finland suggests applying the top-down (general) approach to Divisions 26 and 27 to revise their structure afresh. There might be a new, more appropriate way of differentiating the manufacture, for example manufacture of multipurpose electronics vs. manufacture of single-purpose digital device that produces digital sound and/or images.

France ________________________________________________________________________

France position :

We think it is a good idea to improve NACE notes (even CPA notes).

________________________________________________________________________

But we want to mention some points :

- Notes should not mention registered marks as Apple or JBL.

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- Manufacture of drones should not be classified in 26 Manufacture of computer, electronic and optical products, but rather in 30 Manufacture of other transport equipment.

- We should add in NACE notes the manufacture of tablets computers.

- How to classify manufacture of multi-fonction equipment ? For example bluetooth speaker ceiling light (smart ceiling light with bluetooth : https://www.amazon.co.uk/Ceiling-Bluetooth-Speaker-Dimmable-Diameter/dp/B019E0ESP4) or connected miror (smart mirror : https://www.smart-mirror.fr/).

- NACE should define what is a peripheral equipment : is it only peripheral equipment for computers ? Today there’s a lot of peripheral equipment that are not connected to computers but rather to phones for example. Some peripheral equipment (e.g. virtual reality helmets) can be used without computers. Where should we classifiy these peripheral equipments ?

______________________________________________________________________________

France proposal :

- We think a new organisation of division 26 should be considered : we think that the limits to classify between 26.20, 26.30 and 26.40 are blurred today. The criteria of classification in 26.20 seems to be the fonctionnality and the criteria in 26.40 seems to be the buyers : are such criteria relevant ? Where should we classify peripheral equipment not made for computers ?

_______________________________________________________________________________

France already sent

Germany Agree

Greece we agree with the proposal.


Our proposal:

Tablet: 26.20

Sut-top box: 26.30

Blu-ray players: 26.40

Apple TV: 26.40

Drone: 30.30

VR headset: 26.20

JBL: 26.40

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Italy Italy agrees on the fact that it is necessary to include in the explanatory notes of NACE the references to all these new items listed by Hungary. However, we should pay attention to at least two issues: 1) we should not cite any brand name or trademark such as Apple; 2) we should not cite specific items since that they are part of a sector which evolves very fast (for instance, blue-ray players have almost disappeared). As a consequence, we should find some ways to describe such items that may last for a sufficient period of time and being sufficiently comprehensive. For example, we could use wording such as “game devices”, “smart televisions” and so on.

Italy would like also to point out that NACE groups 26.2, 26.3 and 26.4 should be reanalysed and restructured probably on the basis of “new” criteria.

Some preliminary questions, for example, that we should address could be the following: Can a smart tv still be considered as just a television? Should a smartwatch be considered as a watch or as telephone? And a smartphone, is it just a telephone or a real computer?

A principle based on the “legacy” of the product may be used; for example, the smartphone is the evolution of the telephone which historically has been developed to communicate so manufacture of smartphone should be classified in NACE class 26.30. However, such a principle has some limitations and the respective markets should be analysed in order to find similarities between the different producers of all these items.

Lithuania We agree on this proposal. But the drones should be included in class 30.30

Malta no comment

Netherlands Agree, expanding the explanatory notes would be useful.

Poland We support Hungary's proposal of adding in the explanatory notes provided examples, but among those examples types of products should be mentioned , not invented names of the products. Such as "gaming console" not "X-box". It would be advisable for “Apple TV” to specify this product more general.

Slovenia We agree with the inclusion of these cases in the explanatory notes.

Sweden We think we are not the only ones not in favour of using brand names as explanatory notes. Better to try and use names like “disc-players”, “game consoles”, “set-top-box” etc. Every member state can then use whichever brand names they want in their own national system for classifications.

Switzerland The current division 26 is difficult for BR operators to interpret. It should probably be simplified and the explanatory notes improved. It is also important to define rules to know what prevails in the case where a company produces electronic (division 26) and electrical (division 27) devices (example: headphone producer)

This sector is developing rapidly. It is necessary to find a compromise between too many details and general.

United Kingdom Agree in principle, however, given the innovation within the industry, it is likely that named products will be rapidly superseded. We need to take care that it cannot be inferred that we are specifically referencing a brand. Perhaps expanding the explanatory notes and the use of more generic terms might work well in the long run.

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AT: We don´t know, how is best the restructuring of 26.2, 26.3, 26.4. We think, that we neeed data on the activities of these classes, but the explanatory notes should be changed, the difference between electronic and electric is not clear and flowing and should be eliminated. We propose to include an new class for smart products, for mulitfunctional products, for instance which are not only used for telecommunication, but also for entertainment...

HU: electronic-electric criteria I think is not good, not enough. This is the basis for the distinction between sectors 26 and 27. but now we are talking about the criterion within 26.DK: we need to discuss

RECOMMENDATION:Do not mention in the explanatory notes brands neither technologies that could become outdated very fast. List of terms to be proposed by the members of the TF. Some examples were digital devices that produce digital sound and/or images, digital game devices, game console, set-top-box, smart televisions, etc.

Proposal 61PROPOSAL: 4. Code: 26.30 - Manufacture of communication equipment Proposal: Adding

"Manufacture of smartphones and smartwatches" to the notes of the class 26.30 - Manufacture of communications equipment. Submitted by: Poland Please provide your comment on this proposal:

Austria Austria agrees to include “smartwatches”, because smartphones are mobile phones and already mentioned


Denmark Not sure about adding these. Maybe we need to rearrange some of the content. Smartphones are more like computers nowadays.

Finland Finland disagrees with the proposal to place manufacture of smartwatches to Class 26.30 in the current NACE. Finland agrees with the proposal to add inclusion of manufacture of smartphones to explanatory notes of Class 26.30.

Currently, Class 26.52 Manufacture of watches and clocks indeed does NOT seem appropriate for manufacture of smartwatches. The class seems to have an emphasis on single-purpose use (measuring time) and somewhat on mechanical/analogue machinery.

Many classes under Division 26 have fused to a great extent. Manufacture of (multipurpose) consumer electronics is often hard to distinguish from manufacture of (multipurpose) communication equipment. Moreover, the borderline between household and professional use has blurred.

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France

_______________________________________________________________________

France position :

We agree with the proposal

_______________________________________________________________________

---------------------Manufacture of smartphones :

The manufacture of smartphones is classified in 26.30.22 Telephones for cellular networks or for other wireless networks.

Notes related to the previous proposal (proposal 3) : Today a smartphone is not only a communication equipment, it can be used as a computer, as a display peripheral equipment, as photographic and video cameras, … ⇒ should we rethink the organisation of division 26 ?

cf proposal 3 :

- NACE should define what is a peripheral equipment : is it only peripheral equipment for computers ? Today there’s a lot of peripheral equipment that are not connected to computers but rather to phones for example. Some peripheral equipment (e.g. virtual reality helmets) can be used without computers. Where should we classifiy these peripheral equipments ?

- We think a new organisation of division 26 should be considered : we think that the limits to classify between 26.20, 26.30 and 26.40 are blurred today. The criteria of classification in 26.20 seems to be the fonctionnality and the criteria in 26.40 seems to be the buyers : are such criteria relevant ? Where should we classify peripheral equipment not made for computers ?

---------------------manufacture of smartwatches :

In France, we classify the manufacture of smartwatches in 26.30 Manufacture of communication equipment (26.30.23)/

Notes : the fact that a product is connected or connectable is not a relevant criterion for NACE. Products are classified first according to the activities that produce them, then according to their intrinsic characteristics. And so, the fact of being connected has no reason to change the classification of a product.

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A connected fridge equipped with touch screen and cameras (to take a look in the fridge once in the supermarket) and managing food stocks by indicating which products to consume first, remains a fridge and will be classified with household appliances. A connected lawnmower remains a lawnmower, a connected garment remains a garment, etc.

About this instruction and explanation, a French business register agent precised that a smartwatch when connected give access to a lot of services, but an unconnected smartwatch is still a watch and have the same functionality as a watch : it gives the time ; so why make a difference between other connected objects and connected watch ?

On a more general view, we will add the problem of connected objects in general concertation feedbacks : for example connected mirrors.

France already sent

Germany Agree

Greece we agree to add the manufacture of smartphones in the class 26.30 but concerning smartwatches we believe that it would be better to classify them in class 26.52.


Italy Italy agrees with Poland on the need to add the manufacture of smartphones and smartwatches to the NACE classification, but we are not sure of the class 26.30. NACE groups 26.2, 26.3 and 26.4 should be reanalysed and maybe restructured; see comment to proposal 3.

Lithuania We agree on this proposal.

Malta no comment

Netherlands This is a valuable addition to the explanation. An additional comment under exclusion under 26.5 would be useful.

Poland Although it is our proposition, let us consider whether instead of explicitly pointing the smartwatch, it should be specify as "Manufacture of smartwatches and smartwatch accessories". Maybe such a wider notation will also be indicated due to the possibility of taking into account for example pedometers.

Slovenia In CPA 26.30.22 Telephones for cellular networks or for other wireless networks

we have already smartphones.

We can also add smart watches.

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Sweden Agree.

Switzerland It could also be considered for classification as 2640 - Manufacture of consumer electronics. How can we define the boundary?

Does class 2640 still have a meaning? Shouldn't we classify it in 2620?

This sector is developing rapidly. It is necessary to find a compromise between too many details and general.

United Kingdom Agree

RECOMMENDATION:Add manufacture of smartwatches and smartwatch accessories to the explanatory notes of 26.30. Exclude them from 26.52. Add manufacture of smartphones and smartphone accessories to the explanatory notes of 26.30.

Proposal 62PROPOSAL: 5. Code: 26.51 - Manufacture of instruments and appliances for measuring,

testing and navigation Proposal: In NACE manufacture of pulse (signal) generators is classified in class 26.51. CPA 27.90.45 Title: Electro-magnets; electro-magnetic couplings and brakes; electromagnetic lifting heads; electrical particle accelerators; electrical signal generators and other electrical equipment n.e.c. Submitted by: Austria Please provide your comment on this proposal:

Austria Austria proposes to move the production of pulse (signal) generators to 27.90 in order to avoid inconsistency to CPA ( 27.90.45).

Croatia Need to be harmonized – manufacture of pulse generators should be classified under manufacture of electrical equipment (27.90). There is also a link CN 8543 20 00 Signal generators, electrical – CPA 27.90.45

Denmark Revise link

Finland Firstly, CPA uses both terms "electro-" and "electrical". NACE seems to differentiate between "electronic" and "electrical". Is the difference between "electronic" and "electrical" clear-cut? See for example a note of exclusion in Class 26.11: "This class excludes: […] - manufacture of similar devices for electrical applications, see division 27".

Finland suggests either

a. re-arranging Divisions 26 and 27 to classify manufacture of all similar components and devices to one and the same class, or

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b. clarifying the explanatory notes for inclusions and exclusions to avoid possibility for ambiguous interpretations.

Secondly, NACE class 26.51 includes manufacture of both electric and non-electric instruments and appliances. The whole Group 26.5 seems a bit strange under the division titled as Manufacture of computer, electronic and optical products.


France Pulse generators are electronic test instruments that are used to generate pulses. They can also be used to generate pulses that can simulate a logical circuit, or for example used with oscilloscope as the measuring device

In current classifications :

There’s an inconsistence between ISIC, NACE and product classification.

ISIC :

2651 Manufacture of measuring, testing, navigating and control equipment

——manufacture of mine detectors, pulse (signal) generators; metal detectors

NACE :

26.51 Manufacture of instruments and appliances for measuring, testing and navigation

- manufacture of mine detectors, pulse (signal) generators; metal detectors

So normally, the product « pulse (signal) generator » should be classified in 26.51.xx.

However, such products are not mentioned in CPA 26.51.xx ; but we can find them in CPA notes of 27.90.45 Electro-magnets; electro-magnetic couplings and brakes; electro-magnetic lifting heads; electrical particle accelerators; electrical signal generators and other electrical equipment n.e.c.

This is confirmed in the CN-CPA correspondence table which links 8543 20

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00 Signal generators, electrical with CPA 27.90.45.

In the previous classifications :

In NACE 2003, pulse generators where classified in « 31.62 Manufacture of electrical equipment n.e.c. » and CPA « 31.62.13 Electrical machines and apparatus having individual functions ».

In correspondence table CPA2002-CPA2008 for 31.62.13 we can find a link for « 27.90.40 Other electrical equipment n.e.c. (including electro-magnets; electro-magnetic couplings and brakes; electro-magnetic lifting heads; electrical particle accelerators; electrical signal generators) ».

_________________________________________________________________________________

France notes :

- Is there signal generators other than electrical ?

- We think that we shouldn’t modify a classification in NACE from a correspondence table CN-CPA. Normally a product generated by an activity mentioned in NACE should have a correspondence in CPA.

It is not because a priori a link exists in a correspondence table that we should automatically modify NACE. We should ask ourselves if CPA is right or wrong.

⇒ Is a signal generator an electrical or electronic component ?

___________________________________________________________________________________

France already sent

Germany Agree with correcting CPA

Greece we believe that the manufacture of pulse (signal) generators is better to classify in class 26.51 and not in class 27.90 according CPA because is not just an electric or motor generator. A signal generator is an electronic device that generates repeating or non-repeating electronic signals in either the analogue or the digital domain. Moreover the explanatory notes in class 27.90 of NACE Rev.2 exclude the generators.

Hungary Hungary: Really to include the manufacture of pulse (signal) generator in NACE 26.51, therefore we think that need to correct the 27.90.45 CPA title.

Italy One of the class inclusions of NACE 26.51 contains the following description: “manufacture of mine detectors, pulse (signal) generators; metal detectors”. Our impression is that pulse (signal) generators are something related to mines and different from the products included in CPA 27.90.45. Indeed in our national version we have identified a sixth digit code which

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may be translated as “Manufacture of flame and combustion detectors, mine detectors, motion detectors, pulse generators and metal detector”.

Lithuania We agree on this proposal. This should be harmonized between classifications.

Malta Harmonization between CPA and NACE should prevail.

Netherlands The proposition is unclear. If the point is that NACE and CPA are not consistent, then this should be investigated and fixed.

Poland Electric signal generators are listed by name in subcategory CPA 27.90.45 (Electro-magnets; electro-magnetic couplings and brakes; electro-magnetic lifting heads; electrical particle accelerators; electrical signal generators and other electrical equipment n.e.c.)

Alternatively:

1) remove the indent relating to the production of signal generators from the explanatory notes in NACE 26.51 and add them in the notes of 27.90, or

2) remove signal generators in CPA 27.90.45, including linkage to CN and create a new CPA grouping in chapter 26.51, then NACE will remain unchanged.

Slovenia Move manufacture of pulse (signal) generators from CPA 27.90.45 to CPA 26.XX.XX or move them from class NACE 26.51 to class NACE in division 27.

Sweden Clarification needed.

Switzerland Same conclusion as for the pealable, the limit between 26 and 27 is too blurry.

United Kingdom To help inform discussion: NAICS 2017 gives the following (Correlation to NACE Rev 2 shown in brackets)

334515 (26.51) Pulse (i.e., signal) generators manufacturing

Agree the classification of Pulse (signal) generators should be congruent in NACE/CPA

RECOMMENDATION:A pulse generator is either an electronic circuit or a piece of electronic test equipment used to generate rectangular pulses. Pulse generators are used primarily for working with digital circuits, related function generators are used primarily for analog circuits. Therefore, its manufacture fits better in 26.51.Remove signal generators in CPA 27.90.45, including linkage to CN and create a new CPA subclass under 26.51

Proposal 63PROPOSAL: 6. Code: 27.11 - Manufacture of electric motors, generators and

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transformers Proposal: Manufacture of battery chargers: before the last revision, Subclass 46122 ("Ballasts for discharge lamps or tubes; static converters; other inductors") of CPC Ver. 1.1 (s. https://unstats.un.org/unsd/cr/registry/regcs.asp?Cl=16&Lg=1&Co=46122) was clearly corresponding with Class 3110 ("Manufacture of electric motors, generators and transformers") of ISIC Rev. 3.1 (s. https://unstats.un.org/unsd/cr/registry/regcs.asp?Cl=17&Lg=1&Co=3110). At the last revision the subclass was split (s. https://unstats.un.org/unsd/cr/registry/regso2.asp?Cl=17&Co=3110&Lg=1): "Manufacture of electric motors, generators and transformers, except turbine-generator sets" is classified in Class 2710 ("Manufacture of electric motors, generators, transformers and electricity distribution and control apparatus") of ISIC Rev. 4 (s. https://unstats.un.org/unsd/cr/registry/regcs.asp?Cl=27&Lg=1&Co=2710) and "Manufacture of battery chargers, rectifiers, solid-state inverters" is classified in Class 27.90 ("Manufacture of other electrical equipment", s. https://unstats.un.org/unsd/cr/registry/regcs.asp?Cl=27&Lg=1&Co=2790). Since the last revision Subclass 46122 ("Ballasts for discharge lamps or tubes; static converters; other inductors") of CPC Ver. 2.1 (with the HS 2012 codes 8504.10, 8504.40 und 8504.50) is corresponding with the ISIC Rev. 4 codes 2710 und 2790 (s. https://unstats.un.org/unsd/cr/registry/regcs.asp?Cl=31&Lg=1&Co=46122). Therefore, subclass 27.11.50 ("Ballasts for discharge lamps or tubes; other inductors") of CPA 2.1 has got contents of class 27.90 of NACE Rev. 2. At least that's how I would understand it. The production of the chargers would then probably have to be classified in NACE Rev. 2 class 27.90. Submitted by: Austria Please provide your comment on this proposal:

Austria Austria proposes to classify the manufacture of battery chargers to 27.90.

Croatia Manufacture of battery chargers is classified in 27.90

Denmark We agree that chargers are classified in 27.90, so CPA should be revised accordingly.

Finland We did not quite grasp what was exactly proposed. Was the concern that either CPA 27.11.50 should be cleaned from products corresponding to manufacture in NACE 27.90 - or vice versa?

Finland agrees to harmonise CPA and NACE but has no position in whether it is NACE or CPA which should adapt.

France

For the manufacture of chargers, you will find below an analyse from Marie-Madeleine Fuger on battery chargers for electrical cars.

In CN, 4 products can correspond to electric cars chargers/charging station :

- CN 8504 40 55 (Battery chargers with converter) ⇒ 27.11.50

- CN 8544 42 90 (Battery chargers without converter) ⇒ 27.90.44

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and the charging station :

- CN 8536 69 90 (charging station for electric cars without payment terminal) ⇒ 27.33.13

- CN 9028 30 90 (charging station for electric cars with payment terminal) ⇒ 26.51.63

__________________________________________________________________________

France position : We don’t have a clear opinion on this proposal

We could add an exclusion in CPA and NACE notes for this product with a reference to CPA 27.90

__________________________________________________________________________

France already sent

Germany Agree and shift accumulator chargers (CN 8504 40 55) from CPA 27.11.50 to CPA 27.90.

Greece we believe that the production of battery chargers is classified in class 27.90.

Hungary Hungary:

NACE 27.11

- manufacture of power generators (except battery charging alternators for internal combustion engines)

NACE 27.90

- manufacture of battery chargers, solid-state

If possible, we aggre that will be classified under one code, uniformly in 27.90

Italy The Italian national version already includes the manufacture of battery chargers in class 27.90.

Lithuania We have Prodcom code for this 27904400

Malta no comment

Netherlands The coding of manufacture of battery chargers for cars should indeed be carefully examined in light of future growth of this product.

Poland NACE 27.11 - includes, among others production of battery chargers. CPA

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27.11.50 (Ballasts for discharge lamps or tubes, other inductors) is linked to CN-2019 8504 40 55 [Accumulator chargers (excl. Of a kind of with telecommunication apparatus, automatic data-processing machines, and units of polycrystalline semiconductor rectifiers )].

NACE 27.90 - includes, among others production of converters used in telecommunications equipment (CN 8504 30 00, CN 8504 40 82, CN 8504 40 84, CN 8504 40 88, CN 8504 40 90, CN 8504 90 99).

We suggest adding information to the explanatory notes:

1) NACE 27.11, that the class includes the production of battery chargers, excluding converters of a kind used with telecommunications equipment, automatic data-processing machines and their devices (falling within the scope of 27.90),

2) NACE 27.90 that the class includes the production of chargers for telecommunications equipment and devices for automatic data processing (eg phones, laptops, etc.).

Slovenia We agree that the production of battery chargers should be classified in NACE class 27.90 (CPA 27.90.11 Electric machines and apparatus having individual functions).

Sweden Inconsistency? In favour of a review.

Switzerland No opinion. We do not use CPA and PRODCOM directly in Switzerland


AT: We don´t agree with the 4 CN positions that France proposed for electric car changing stations. Can you please contact CN experts for these codes, because these activities are becoming more important.

RECOMMENDATION:The production of battery chargers should be classified in NACE 27.90 and the product on CPA 27.90.11 Electric machines and apparatus having individual functions.

Proposal 64PROPOSAL: 7. Code: 28.11 - Manufacture of engines and turbines, except aircraft,

vehicle and cycle engines Proposal: Another tricky point for us is the classification of vehicle engines (vehicle engines in 29.10, airplanes in 30.30, tractors, boats and other engines in 28.11). This explosion does not always seem very logical to us (and to companies either). In addition, we encountered electric motors not explicitly mentioned in the nomenclature. Submitted by: France Please provide your comment on this proposal:

Austria Austria is against a change, because this would cause too many changes. This structure was since NACE Rev.1. Electric motors are already

22

mentioned.

Croatia We do not have information from our BR colleagues that there is a problem with classification in this area, so we need more information on this. In addition, manufacture of electric motors (except starting motors) is mentioned in 27.11, but explanatory notes can be improved so that classification of vehicle engines would be becomes clearer.

Denmark The engines are divided into general purpose (28), motor vehicles, trailers and semi-trailers (29) and other transport equipment (30) - that seems quite logical

Electrical motors should of course be added to the notes in the respective classes.

What about electrical motors for bicycles and scooters and the like?

Finland We would appreciate more details on "electric motors not explicitly mentioned in the nomenclature".

We handled Q7 and Q8 together:

We observe manufacture of motors for vehicles, and manufacture of parts for those motors in 5 different classes and in 3 different divisions:

27.11 Manufacture of electric motors, generators and transformers

27.20 Manufacture of batteries and accumulators

28.11 Manufacture of engines and turbines, except aircraft, vehicle and cycle engines

29.10 Manufacture of motor vehicles

29.31 Manufacture of electrical and electronic equipment for motor vehicles

The activity is small in size in Finland, so Finland does not have any strong position in the matter. We would adapt to the decision to move all manufacture of parts of motor vehicles and their engines to one and the same division - but we do not have any problem keeping the current structure either.

However, Finland would like to add a question on manufacture of non-combustion engines for motor vehicles, e.g. electric engines. Will manufacture of non-combustion engines for motor vehicles be classified in 27.11? The update/revision of NACE should be relevant and accurate for at least 10 years to come. It is probable that the use of a variety of types of engines for motor vehicles will grow fast. Please consider our discussion on biofuels in Survey 1 Questions 36, 37, 48, 50 and 51.

France The manufacture of engine is disseminated in NACE and CPA with different criteria (process and destination)

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- 27.11 Manufacture of electric motors, generators and transformers

- 28.11 Manufacture of engines and turbines, except aircraft, vehicle and cycle engines (marine engines)

- 28.12 Manufacture of fluid power equipment

- 29.10 Manufacture of motor vehicles

- 30.30 Manufacture of air and spacecraft and related machinery

- 30.91 Manufacture of motorcycles

Attention : our initial proposal concerning « in addition, we encountered electric motors not explicitly mentioned in the nomenclature. » is irrelevant.

---------------> There’s a problem to collect precise data on engine, particularly for new engines (technological secret), is it necessary to have a so detailed CPA ? Surveys agents needs 3 criteria to classify : alternating current / direct current, single-phase/polyphase, output.

______________________________________________________________________________________

France notes :

- It’s a problem with priority of criteria : what is the most important : the process or being a part of an equipment ?

- as a part of equipment, why aren’t electric motors for vehicles included in 29.10 ?

- There’s no catch-all class in CPA for AC engines that could be new and won’t conform to current criteria.

- Remark of yearly production survey team :

• For aeronautics, the classification of engines in 30.30 does not seem illogical insofar as the conception and assembly of engines are closely linked to the product and its characteristics. Moreover, the companies that produce these engines do not manufacture for other industries such as the automotive or railway industry.

• Proposal : Classify propulsion or propulsion support engines (power units in aeronautics) in NACE of each associated transport equipment, regardless of the nature of the electric motor, diesel, petrol or other. Thus aircraft engines are to be classified in 30.30, boat engines in 30.11......The other engines considered as auxiliary and therefore less specific would remain in 28.11.

_____________________________________________________________

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___________________________

France already sent

Germany With the last revision of ISIC and NACE numerous contents outside the manufacture of vehicles and the manufacture of other transport equipment was shifted inside these classes (e.g. manufacture of motor vehicle electrical equipment, manufacture of car seats, railway car seats and aircraft seats). This is in line with the general rule in the explanatory notes for section C that manufacture of specialised components and parts of, and accessories and attachments to, machinery and equipment is, classified in the same class as the manufacture of the machinery and equipment for which the parts and accessories are intended. We would therefore stick to that underlying concept and keep the manufacture of vehicle engines together with the manufacture of vehicles etc..

Greece Although there are many classes for engines, we believe that there are not exist blur boundaries. In addition we believe that it is difficult to classify in one class all the engines. Maybe a solution would be to integrate the engine into the class of manufacture of vehicle or train or airplanes or ships and boats as it is included in the class of manufacture of motorcycles.

Hungary Hungary: We agree with the proposal. The present system is inconsistent and confusing.

The manufacture of electric motors should be classified into NACE 27.11. The manufacture of all other engines should be classified into 28.11.

Italy The proposal by France should be analysed in a more general way by taking into consideration (or not) the intended use principle (what a product, or an intermediate product, is used for). According to Italy, such a principle (also presented by Italy at the last Standards WG) should be better clarified in general for the NACE and also at the ISIC level. Other proposals have already faced similar considerations; see for example proposal number 53 of the first NACE Review TF consultation.

Are there any examples of enterprises producing both vehicle engines and engines for airplanes?

Concerning the electric motors and according to the intended use principle currently used by NACE, the proposal could be splitting NACE class 29.10 in two classes: 29.10A non-electric motors and 29.10B electric motors.

The alternative choice that means putting the manufacture of electric motors in division 27 seems to be reductive and it is not supported by ANFIA - the Italian Association of the Automotive Industry (https://www.anfia.it/).

Lithuania We don't understand what is the proposal.

Malta We are in favour of the separate delineation of boat, vehicle and tractor engines as the costs (and manufacturing process) may vary significantly. For this reason, we do not agree with France’s proposal. However, agree with the mention that electric motors used for cars should be separately identified.

Netherlands Good idea to clear this. Keep products for end use in one particular category grouped together, for instance, car parts, car engines etc. under 29 and so on. Electric batteries should be included accordingly.

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(explosion should be explanation, I assume)

Poland The proposal is unclear.

If it concerns a change in the current classification of the manufacture of internal combustion engines for various applications (eg by creating one grouping of NACE) - we do not support this proposal.

Production of engines of a type used for propulsion in watercraft (28.11 engines and turbines), in motor vehicles (29.10), in rolling stock (28.11), in air and spacecraft (30.30), of a type used in motorcycles (30.91). Electric motors are listed in the name of the class 27.11 (Manufacture of electric motors, generators and transformers) (CPC 461).

Production of parts for:

1) piston internal combustion engines with spark ignition (28.11)

2) turbojet and turboprop engines (30.30)

3) spark-ignition aircraft engines (30.30)

Internal combustion engines for various types of non-rail vehicles are mainly produced by companies associated with the manufacture of complete vehicles, therefore their inclusion in Division 29 is natural. Similarly with aircraft engine manufacturers. The manufacture of combustion engines for the propulsion of watercraft / railway / industrial is classified in Division 28. Removal of marine / railway engine manufacture from Division 28 and inclusion in divisions in which ship / rolling stock manufacture is classified would not be reasonable, because the scale of production does not justify the unfavorable impact of change on classification stability. The combustion engines of ships and railways do not differ much from industrial engines (eg used for power generation) and in many cases are produced by the same producers. The removal of manufacture of internal combustion engines, for various applications, to one division (class) - does not seem to be reasonable.

Slovenia Are not electric motors classified in CPA 27.11.1 Motors of an output ≤ 37,5 W; other DC motors; DC generators and Universal AC/DC motors of an output > 37,5 W; other AC motors; AC generators

(alternators)? We agree with the classification of vehicle engines by type of vehicle.

Sweden Agree. Any suggestions? Electric motors is included in 27.1 however not explicitly vehicle motors.

Switzerland This question concerns a change at the division level.

United Kingdom There is strong support at the national level for continuing the current practice of classifying such engines in line with their final product; particularly those relating to aerospace and automotive engines.

PL: We propose to classify the production of engines other than internal combustion engines together with internal combustion engines. Add in the explanatory notes of NACE 27.11 that the class excludes electric motors for motor vehicles.

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HU: motor vehicles are in 29.10, then I would also classify electric motor motor in 29.10. In this case, a new item should be created in CPA 29.10: 29.10.14 Electric engines for vehicles.

RECOMMENDATION:Proposal rejected. The present classification of engines follow the general rule of Section C saying that the manufacture of specialised components and parts of, and accessories and attachments to, machinery and equipment is, as a general rule, classified in the same class as the manufacture of the machinery and equipment for which the parts and accessories are intended.Manufacture of non-combustion engines for motor vehicles, e.g. electric engines should be classified in 29.10 together with internal combustion engines.

Proposal 65PROPOSAL: 8. Code: 28.11 - Manufacture of engines and turbines, except aircraft,

vehicle and cycle engines Proposal: The manufacturing of parts for combustion engines is classified in general in division 28 - also of those for motor vehicles. This is different to NACE Rev. 1.1 which distinguished between parts for the different types of engines and leads to the neglect of a large portion of production directly linked to the manufacture of motor vehicles. Proposal: Moving the manufacture of parts for motor vehicles combustion engines to division 29. Submitted by: Germany Please provide your comment on this proposal:

Austria Austria agrees with this proposal, because parts for combustion engines for vehicles should be classified where the engines are classified.

Croatia Manufacture of electrical equipment and components of internal combustion engines is included in 29.31. We need more information on this.

Denmark General purpose parts, should stay in 28, whereas parts that is not could be classified with the type of engines that they belong to - if deemed necessary

Finland We observe manufacture of motors for vehicles, and manufacture of parts for those motors in 5 different classes and in 3 different divisions:

27.11 Manufacture of electric motors, generators and transformers

27.20 Manufacture of batteries and accumulators

28.11 Manufacture of engines and turbines, except aircraft, vehicle and cycle engines

29.10 Manufacture of motor vehicles

29.31 Manufacture of electrical and electronic equipment for motor vehicles

The activity is small in size in Finland, so Finland does not have any strong position in the matter. We would adapt to the decision to move all manufacture of parts of motor vehicles and their engines to one and the same division - but we do not have any problem keeping the current structure either.

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However, Finland would like to add a question on manufacture of non-combustion engines for motor vehicles, e.g. electric engines. Will manufacture of non-combustion engines for motor vehicles be classified in 27.11? The update/revision of NACE should be relevant and accurate for at least 10 years to come. It is probable that the use of a variety of types of engines for motor vehicles will grow fast. Please consider our discussion on biofuels in Survey 1 Questions 36, 37, 48, 50 and 51.

France France position :

Manufacture of part of engine should be classified with manufacture of the engine.

CPA heading « 28.11.4 Parts for engines » excludes only

- parts for aircraft spark-ignition engines, see 30.30.15

- parts of turbo-jets or turbo-propellers, see 30.30.16

There should be other exclusions to products of 29 (for parts of motor vehicles combustion engines).

cf proposal 7

___________________________________________________________________________________

France proposal :

proposal 1 : (we are in favor of this proposal) Either the manufacture of engines is classified with the manufacture of transport equipment, the parts of engines are also added;

proposal 2 : (we are not in favour of this proposal) or all engines are classified together, with their parts and distinguished by type of engines, but they are no longer linked to the transport equipment

____________________________________________________________________________________

France already sent

Germany Agree

Greece Comment same as proposal 7.

Hungary Hungary: It is related to the previous question; if the proposed breakdown for the previous question is accepted, then the parts will be there as well.

Italy ANFIA - the Italian Association of the Automotive Industry (https://www.anfia.it/) agrees with the proposal by Germany and has

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provided a set of other new proposals to reorganize NACE divisions 28 and 29 which have been sent to Eurostat at the end of June as new proposals.

Lithuania Not relevant for Lithuania. But we have units that manufacture the parts for engines, we think there is a reason why parts is in general class.

Malta Fully agree. The current guidelines vis-à-vis manufacturing of engines are scattered between NACE 28 and 29. The process (part of the engine or full) should be classified in one industry.

Netherlands Agree.

Poland We support the proposal. For the sake of legibility, we suggest to add that class 29.10 also includes parts for engines for motor vehicles.

Slovenia We agree to move the manufacture of parts for motor vehicles combustion engines to division 29.

Sweden We agree! We use 29.101 (Manufacture of passenger cars and other light motor vehicles) for the manufacture of motor vehicles engines.

Switzerland Ok with the proposal


RECOMMENDATION:Explanatory notes of 29.10 will include parts of motor vehicles combustion engines. That means moving these parts from division 28 (where they are now) to division 29.

Proposal 66PROPOSAL: 9. Code: 28.21 - Manufacture of ovens, furnaces and furnace burners

Proposal: Manufacture of heat pumps - inconsistency between CPA and NACE: CPA 28.25.13. resp. PRODCOM 28.25.13.80 and NACE 28.21. Submitted by: Austria Please provide your comment on this proposal:

Austria Austria: There is an inconsistency between NACE and CPA and PRODCOM and this inconsistency should be eliminated.

Croatia It is necessary to harmonize the classification of heat pumps, so we think that manufacturing of heat pumps should be included in NACE 28.21.

Denmark Revise the link

Finland Finland agrees that there is a discrepancy in treatment of heat pumps and that harmonisation is needed. For heating, only NACE mentions heat pumps and restricts them to domestic use. For cooling and ventilation, NACE ignores them but CPA and PRODCOM mentions heat pumps and restricts them to non-domestic use.

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The discrepancy or discontinuity between classifications in more detail:

1. Heat pumps interpreted as furnaces to create heat

- Heat pumps are explicitly mentioned only in NACE 28.21

- CPA 28.21… or PRODCOM 28.21… do not mention heat pumps

- NACE explicitly restricts manufacture to HOUSEHOLD-TYPE furnaces such as heat pumps. Similar emphasis lacks from CPA and PRODCOM.

2. Heat pumps interpreted as cooling and ventilation equipment

- NACE 28.25, CPA 28.25… and PRODCOM 28.25… all explicitly EXCLUDE THE DOMESTIC USE.

- NACE does not mention heat pumps at all whereas both CPA and PRODCOM do.

- PRODCOM 28.25.12.50 Air conditioning machines with refrigeration unit refers to CN: 8415[.81 + .82]

- PRODCOM 28.25.13.80 explicitly excludes products described in HS 8415: "Heat pumps other than air conditioning machines of HS 8415"

France _______________________________________________________________________________

France position :

There’s an inconsistency between NACE and classification of products.

We don’t have a solution but we think that 3 criteria should be taken into account (or be considered irrelevant) when we decide to classify the manufacture of heat pumps :

- for household purpose / except household purpose (non domestic purpose)

- reversible heat pump / non reversible heat pump (only cold ? or only heat ?)

- considered part of equipment or not ?

If we have to decide a unique classification for manufacture of heat pump, we would prefer 28.25

_______________________________________________________________________________

France notes :

This inconsistence already existed in NACE Rév1, class « 29.23 Manufacture of non-domestic cooling and ventilation equipment » contained :

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– manufacture of refrigerating or freezing industrial equipment

– manufacture of air-conditioning machines

– manufacture of heat exchangers *

This class excludes :

– manufacture of domestic refrigerating or freezing equipment, see 29.71

and CPA 29.23.13 Refrigeration and freezing equipment and heat pumps, except household type equipment

French yearly production survey team :

In NACE rev1, air-conditioning, refrigeration and heating equipment were grouped together in a single NAF. The transition to NACE Rev 2 resulted in refrigerating and air conditioning equipment on the one hand and heating equipment on the other.

If we follow this logic, only heat pumps producing only heat should be in 25.21Z, the other heat pumps (cold or reversible) should be in 28.25Z.

Details on the type of pumps should therefore be included in the wording (especially since for 28.25.13 we have "heat pumps of all types", which is not true).

If we want to group all heat pumps in a single NACE, we prefer class 28.25

ISIC :

2815 Manufacture of ovens, furnaces and furnace burners

——manufacture of electric household-type furnaces (electric forced air furnaces, heat pumps, etc.), non-electric household forced air furnaces

NACE :

28.21 Manufacture of ovens, furnaces and furnace burners

- manufacture of electric household-type furnaces (electric forced air furnaces, heat pumps, etc.), nonelectric

household forced air furnaces

CPA :

28.25.13 Refrigeration and freezing equipment and heat pumps, except household type equipment

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Prodcom :

28.25.13.80 Heat pumps other than air conditioning machines of HS 8415

CN :

8418 61 Heat pumps other than air conditioning machines of heading 84.15 ==> 28.25

8415 Air conditioning machines, comprising a motor-driven fan and elements for changing the temperature and humidity, including those machines in which the humidity cannot be separately regulated ==> 28.25

France already sent

Germany Shifting CN 8418 61 00 ("Heat pumps (excl. air conditioning machines of heading 8415)") from CPA 28.25.13 in a new CPA subcategory in class 28.21.

Greece According to CPA classification we believe that in class 28.25.13 are classified the heat pumps except household type equipment while in class 28.21 of Nace are classified the heat pumps concerning the manufacture of electric household-type furnaces. So we believe that it does not exist inconsistency between CPA and Nace concerning the heat pumps. For us the problem has to do with the use of heat pumps.if they are from household type equipment or not. A solution is to classify the heat pumps from house hold type equipment in class 28.21 and the heat pumps from non household type equipment in class 28.25.


If I compare the content of NACE 28.21 and 28.25 the heat pumps are better matching to 28.25 than 28.21. And the name of CPA 28.25.13 consists of heat pumps. But if the heat pump function is dominant, then 28.21

Italy The manufacture of heat pumps should be classified in NACE class 28.25 so Italy is in favour of moving the content. The manufacture of heat pumps should be removed from 28.21.

Lithuania We agree the links should be harmonized.

Malta no comment

Netherlands Agree to make consistent.

Poland There is an inconsistency between NACE 28.21 and CPA. Heat pumps are mentioned in NACE 28.21. While they are in CPA 28.25.13 and PRODCOM 28.25.13-80 – links to CN 8418 61 Heat pumps (excl. air conditioning machines of heading 8415) or in CPA 28.25.12 reversible heat pumps – linked to CN 8415.

Slovenia We have to consider CPA and PRODCOM versions and classify the production of heat pumps in NACE 28.25.

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Sweden Agree, if there is an inconsistency it needs to be corrected.


United Kingdom Agree, clarity needed to distinguish between the household household-type furnaces (electric forced air furnaces, heat pumps, etc.) in 28.21 (Manufacture of ovens, furnaces and furnace burners)& the non household heat pumps in 28.25.13 (Refrigeration and freezing equipment and heat pumps, except household type equipment)

PL: We agree with the proposal that household heat pumps should be placed in NACE 28.21, CPA 28.21.15. However, the links with CN 8415 81 00 for reversible heat pumps and CN 8418 61 00 for irreversible heat pumps should be borne in mind. Non-household pumps - NACE 28.25:- 28.25.12 CPA (CN 8415 81 00) for reversible heat pumps- 28.25.13 CPA (CN 8418 61 00) for irreversible heat pumps

AT: The distinction between products for household and industrial use should eliminated, because many produtcs can be used both. Your proposal to remain manufacture of household type heat pumps in 28.21 (CPA 28.21.15?) is not in this direction because the heat pumps not household type are in 28.25.13 as you wrote.

RECOMMENDATION:Manufacture of household type heat pumps should remain in 28.21. A CPA sub class needs to be considered (28.21.15?)Non-household heating, cooling and ventilation equipment should remain in in 28.25 (title of class should reflect that heating equipment is also included. The correspondent products should be classified in 28.25.13 Refrigeration and freezing equipment and heat pumps, except household type equipment.Manufacture of household cooling and ventilation equipment should be mentioned in 28.21 explanatory notes. A CPA sub class needs to be considered (28.21.16?). Remove the distinction household vs. industrial use, since these are the same ACs and heat pumps.The issue of the manufacture of heating and cooling systems will anyway be discussed in the discussion forum.


Proposal: Manufacture of parts for heating systems e.g. heating boilers - inconsistency between NACE and CPA resp. PRODCOM: the Manufacture of heating boilers for heaters are classified in PRODCOM 25.21.12.00 and 25.30.11.70. NACE 28.21 includes: "manufacture of permanent mount non-electric household heating equipment, such as solar heating, steam heating, oil heat and similar furnaces and heating equipment." Since parts are always classified together with the whole system, the manufacture of which parts of the heating systems is classified in class 28.21? Submitted by: Austria Please provide your comment on this proposal:

Austria Austria: The same question was raised when we discussed the proposals for division 25. The distinction between 25.21, 25.30 and 28.21 must be clear. We should mention in explanatory notes, what kind of products for heating are produced in 25.21.

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Croatia No comment for now. Explanatory notes need to be supplemented to make it clear what is included or excluded.

Denmark no opinion

Finland We do not observe any inconsistency between NACE, CPA or PRODCOM. Only if there exists a principle according to which manufacture of parts of a system should be classified to the same class as manufacture of the system, there is indeed an inconsistency WITHIN all 3: NACE, CPA and PRODCOM.

The question should be handled together with Survey 1 Question 57. We are not familiar with the principle stated above (manufacture of parts + system), and therefore our answer to Survey 1 Question 57 was as follows:

Finland agrees with the conclusion to improve the explanatory notes [for 25.21 and 28.21], and suggests the following:

- Include in the explanatory notes of 28.21 Manufacture of central heating systems

- Include in the exclusions of 28.21 Manufacture of central heating radiators and boilers, see 25.21

- Include in the exclusions of 25.21 Manufacture of central heating systems, see 28.21

France *******

feedback later

sorry

Nathalie

******

France [Attached to proposal 57 from previous consultation.]

Remark : Prodcom is not a classification, Prodcom is a list (and should be consistent with NACE and CPA).

Heating boiler refers to an apparatus (or even an industrial installation, depending on its power) for the continuous transfer of thermal energy to a heat transfer fluid (most commonly water).

Inside the boiler, this heat transfer fluid can either be heated only (i.e. it remains in liquid phase), heated and vaporized, or heated, vaporized and then superheated (i.e. with passage from liquid phase to gas phase).

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France position :

In France, we classify

- the manufacture of steam generators for industrial or energy purposes, designed to power turbines or produce steam or superheated water in 25.30.11 ;

- the manufacture of central heating boilers in 25.21.11. The difference is the purpose : central heating in 25.21, industrial/energetic purpose in 28.21.

We classify the manufacture of the burners of these heating equipment in 28.21 ; the other parts are classified with the manufacture of the equipment.

Germany Shifting manufacture of central heating boilers from class 25.21 to class 28.21 and correspondingly also of CPA subcategories 25.21.12 ("Central heating boilers, for producing hot water or low pressure steam") and 25.21.13 ("Parts for central heating Boilers").

Greece According to PRODCOM classification we believe that in class 25.21.12 and 25.30.11 are classified only the heating boilers used for the heating while in class 28.21 of Nace are classified only the burners used for the heating. So, we believe that it does not exist inconsistency between CPA, PRODCOM and Nace because boilers and burners are two different parts of a heating system and have also a different classification.

Hungary Hungary:

NACE 25.21 Manufacture of central heating radiators and boilers

CPA 25.21.12 Central heating boilers, for producing hot water or low pressure steam

PRODCOM 25.21.12.0 Boilers for central heating other than those of HS 8402

PRODCOM 25.21.13.0 Parts of boilers for central heating

The manufacture of which parts of the heating systems is classified in class 28.21? See PRODCOM 28.21.14.0:

NACE 28.21 Manufacture of ovens, furnaces and furnace burners

CPA 28.21.14 Parts of furnace burners, furnaces and ovens

PRODCOM 28.21.14.0 Parts for furnace burners for liquid fuel, for pulverised solid fuel or for gas, for mechanical stokers, mechanical grates, mechanical ash discharges and similar appliances

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We don’t agree with the proposal. There is no inconsistency between NACE and CPA 28.21. You can find more details in PRODCOM 28.21.14.0.

Italy NACE class 28.21 should contain only the metal container.

Lithuania We agree. It is not clear. The explanatory notes should be refined

Malta Agree

Netherlands Agree to make clear.

Poland It would be worth considering whether to remove an indent from NACE 28.21:

- "manufacture of permanent mount non-electric household heating equipment, such as solar heating, steam heating, oil heat and similar furnaces and heating equipment" and transfer permanent mount non-electric household heating equipment to NACE 27.52 (CPA 27.52.14 Water heaters, instantaneous or storage, non-electric).

Slovenia In such cases, we believe that it is necessary to harmonize all three of the above mentioned classifications (NACE, CPA, PRODCOM), and since PRODCOM is also affiliated with the CN, this connection should be taken into account. In general, there is a problem in cases where these classifications are not harmonized.

Sweden Agree, if there is an inconsistency it needs to be corrected.


United Kingdom Agree, clarity needed

AT: You listed the parts of heating systems in a table, that is good work. We do´t believe that it is easy to have a more rational approach, this would need great changes. The difference between heating systems for household and not household type should be deleted. The explanatory notes of all classes you have mentioned in your table should be enriched, what kind of products are there classified for instance just boilers or boilers with other equipment integrated. DK: It's look very complex

RECOMMENDATION:We couldn’t see any inconsistency but it is true that the manufacturing of heating and cooling equipment is scattered over the classification with criteria that are not always very logic:Manufacturing of heating and cooling equipment

Boilers Burners25.21(1) 25.30(2) 27.51(3) 27.52(4) 28.21 (5) 28.25(6)

Domestic use ? X X X

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Non-Domestic use

X X X

Heating X X X X X X Cooling and ventilation

X X

Electric X ? XNon-electric X ? X XPart of central equipment

X X

Not part of central equipment

X X X X X

Portable X X Not portable X X CPA product 25.21.11

25.21.1225.30.1125.30.12

27.51.1527.51.2627.51.29

27.52.13 28.25.1128.25.1228.25.1328.25.20

(1) Radiator and boilers for central heating(2) Steam generators and boilers not for central heating(3) Space heaters and household type fans portable(4) Non-electric domestic appliances – non electric space heaters(5) Manufacture of ovens, furnaces and furnace burners

a. manufacture of permanent mount electric space heaters, electric swimming pool heaters

b. manufacture of permanent mount non-electric household heating equipment, such as solar heating, steam heating, oil heat and similar furnaces and heating equipment

c. manufacture of electric household-type furnaces (electric forced air furnaces, heat pumps, etc.), non-electric household forced air furnaces

(6) Manufacture of non-domestic cooling and ventilation equipment manufacture of refrigerating or freezing industrial equipment, including assemblies of components - manufacture of air-conditioning machines, including for motor vehiclesmanufacture of non-domestic fans manufacture of heat exchangers

Issue to be discussed in the discussion forum.


Proposal: Refine the name of the class, e.g. „Heating equipment“ or separate class. Classification of solar collectors and other domestic non electric heating equipment (wind, water, geothermal). Submitted by: Lithuania Please provide your comment on this proposal:

Austria Austria agrees with the change of the name, because nobody would

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believe that heating equipment is included here.

Croatia We agree with the proposal – Heating equipment manufacturing.

Denmark Revise the title

Finland Finland agrees with the proposal to revise the name of the class into "Manufacture of heating equipment". Without being a native English speaker, HEATING EQUIPMENT seems to be a valid general title covering all types of equipment listed in the current class. For example, Finland classifies manufacture of geothermal heat pumps to 28.21. These pumps have nothing to do with ovens, furnaces and furnace burners shown in the current class title.

Care should be taken to avoid any conceptual overlapping in the new title and already existing separate classes such as Class 25.21 Manufacture of central heating radiators and boilers.

France

The representative of Data and Statistical Studies Department (SDES - Ministry for the Ecological and Inclusive Transition) is in favour of distinguishing renewable heat.

_______________________________________________________________________

France proposal :

- to improve CPA notes : we can’t find the mention of this activity in CPA notes.

- to isolate non electric heating equipment in CPA (new class)

_________________________________________________________________________

France already sent

Germany Agree with refining or even splitting that class.

Greece We propose to change the name of the class. ex."Manufacture of ovens furnaces and heating equipment" because if the change of the title only mention "heating equipment" it is not clear that this class also includes the manufacture of furnaces ovens and incinerators.

Hungary Hungary: We agree with the changing of the name of the class. The manufacture of solar collectors is classified into 27.52 (CPA 27.52.14).

Italy Italy is not in favour of creating a new class but the activity should be included in the explanatory notes. If more details are necessary, national versions may provide new categories or products classifications may be used. However, is it possible to produce domestic heating from wind or water? Solar and geothermal ok.

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Lithuania Our proposal.

Malta no comment

Netherlands We would be careful to add “Heating equipment” to “Manufacture of ovens, furnaces and furnace burners”. Code 28.21 refers to the industrial type of heating, code 25.11 to Central heating/boilers. Moreover, be careful of coding 35.30 Steam and air conditioning supply, where production, collection and distribution of steam and hot water for heating, power and other purposes is coded.

Poland Modifying the name of this class is not enough. Explanations to the class should be reviewed.

The manufacture of non-electric instantaneous and storage heaters, including solar water heaters, for domestic use or not, is classified in NACE 27.52 (CPA 27.52.14, CN 8419 19 00).

We suggest adding in the explanatory notes that:

- NACE 27.52 includes the manufacture of non-electric instantaneous and storage heaters, including solar water heaters, for domestic use or not

- NACE 28.21 excludes the manufacture of non-electric instantaneous and storage heaters, including solar water heaters, for domestic use or not

Slovenia We are proposing to rename the class.

We are opposed to a separate class because a further breakdown of activities may lead to confidentiality problems in small countries.

Sweden In favour. Better explanatory notes is always welcome.


This class does not contain many companies in Switzerland.


PL: We agree to change the name, but the scope of class 28.21 should be clarified

RECOMMENDATION:Rename 28.21 - Manufacture of ovens, furnaces, furnace burners and household heating equipment. However the scope of the class can be changed following the discussions on the forum

Proposal 69PROPOSAL: 12. Code: 28.4 - Manufacture of metal forming machinery and machine

tools Proposal: The split of ISIC Rev. 4 class 28.22 (“Manufacture of metal-forming machinery and machine tools”) may be executed by splitting the bullet points in the explanatory notes from ISIC, not based on technical

39

aspects. Machine tools for turning, drilling, milling, shaping, planning, boring, grinding etc., mentioned in the explanatory notes from class 28.41, are no metal forming machinery. Proposal of change: Restructuring group 28.4 Submitted by: Germany Please provide your comment on this proposal:

Austria Austria disagrees because in CPA 28.41.22 machines for metal forming are mentioned.

Croatia In our opinion, the current split of group 28.4 is satisfactory. Maybe to change the title of class 28.41, e.g. manufacturing of machine tools for working metal.

Denmark What about combining 28.41 and 28.49 instead?

At least some of the machine tools mentioned are metal forming machinery. We could remove those that are not.

Finland If the English terms of "turning, drilling, milling, shaping, planning, boring, grinding" used in the explanatory notes are not fit for metal forming then Finland agrees with the proposal to cut off the note and to add it to the class 28.49.

The activity is small in size in Finland. A counter proposal of aggregating classes 28.41 and 28.49 (collapsing them) into 28.40 Manufacture of machinery and tools for "hard material" would fit to our national needs as well.

Eurostat could verify the current size of the classes 28.41 and 28.49 in Europe from SBS data.

France France position : We don’t understand clearly the proposal.

If the proposal is to shed light on the following activities to indicate that they are not metal forming machinery, we agree : they are machine tools (metal working machines) :

——manufacture of machine tools for working metals and other materials (wood, bone, stone, hard rubber, hard plastics, cold glass etc.), including those using a laser beam, ultrasonic waves, plasma arc, magnetic pulse etc.

——manufacture of machine tools for turning, drilling, milling, shaping, planing, boring, grinding etc.

Solutions could be :

- to change the heading in NACE « Manufacture of metal forming and metal working machinery » or « Manufacture of metal working machinery » (choice made in french national classification)

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- to merge 28.41 and 28.49 as in ISIC (is it the german proposal?)

________________________________________________________________________________

France proposal :

We are in favour of merging 28.41 and 28.49

________________________________________________________________________________

France already sent

Germany At least renaming class 28.41 from "Manufacture of metal forming machinery" to "Manufacture of metal working machinery".

Greece we agree in part with the proposal of Germany. Undeed some machine tools in this class are not metal-forming tools but if we exlude them where we will classify them? In class 28.49? We propose to change the title of the class. ex "Manufacture of metal machine tools".

Hungary Hungary:

We don’t agree with the proposal. The machinery mentioned are metal forming machinery. Machinery forming other material than metal, is included in NACE 28.49. We think, that the coherence between ISIC and NACE a 2 digit level is ok.

Italy Italy, in accordance with the national association UCIMU (http://www.ucimu.it/home/), is interested in restructuring group 28.4.

First of all, we propose to change the title of the group from “Manufacture of metal forming machinery and machine tools” in “Manufacture of additive technology machinery, metal working and other machine tools”. Two main reasons for this proposal are the following:

1) the importance of additive technology machinery, which is increasing, and

2) the term “forming” is misleading because the metal working machinery industry is composed of metal cutting machines, metal forming machines and machines operating with other technologies like laser, waterjet, EDM.

Secondly, Italy proposes to change the title of NACE class 28.41 from “Manufacture of metal forming machinery” to “Manufacture of metal working machine tools” with a new exclusion: “This class excludes manufacture of additive technology machinery – new class 28.42”. A new class 28.42 should be created “Manufacture of additive technology machinery” for all materials; “traditional” metal working machinery will remain in NACE class 28.41 while other machine tools are in 28.49. Consequently, another exclusion to NACE class 28.49 should be added: “This class excludes manufacture of additive technology machinery – new

41

class 28.42”.

Additive technology is the most relevant innovation in the manufacturing field in the last decades; it is widely used in the space, aeronautics and medical sectors and it allows for new products (impossible to be produced with previous technologies) and extreme personalization.

To sum up, the restructuring proposal is the following:

28.41 Manufacture of metal working machine tools

This class excludes manufacture of additive technology machines (28.42)

28.42 Manufacture of additive technology machinery

This class includes manufacture of machines for additive manufacturing by metal deposit, plastics or rubber deposit, plaster, cement, ceramics or glass deposit and other.

Additive manufacturing means the formation of physical objects, based on a digital model, by the successive addition and layering, and consolidation and solidification, of material.

28.49 Manufacture of other machine tools

This class excludes manufacture of additive technology machines (28.42).

Lithuania If the proposal is to refine the name of the group, we agree.

Malta no comment

Netherlands Seems agreeable.

Poland We do not support Germany's proposal.

The ISIC class (Rev. 4) 2822 is linked to NACE (Rev. 2) - with classes 28.41 and 28.49.

Therefore, the ISIC 2822 class applies not only to metal forming machinery but also to other mechanical tools, while NACE 28.41 class applies only to metal forming machinery.

The NACE 28.41 class is linked to CPA 28.41 and CN codes: 8456, 8457, 8458, 8459, 8460, 8461, 8462, 8463. Machine tools for turning, drilling, milling, shaping, planing, boring, grinding etc. are used for metal forming .

Slovenia We do not understand the proposal. We ask for a more detailed explanation.

Sweden Is this not already divided into 28.41 (manufacture of metal forming machinery) and 28.49 (Manufacture of other machine tools)?

Switzerland no opinion

United Kingdom This has not been raised as a concern by UK, however further clarity would be welcomed

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PL: We agree with the first proposal of recommendations regarding the restructuring of the group 28.4AT: We are in favour of your first proposalDK: support solution 2HU: do not merge 28.41 and 28.49;

RECOMMENDATION:2 proposals to solve the problem:- Proposal 1: Restructuration of group 28.4

28.4 Manufacture of additive technology machinery, metal working and other machine tools. 28.41 Manufacture of metal working machine tools

This class excludes manufacture of additive technology machines (28.42) 28.42 Manufacture of additive technology machinery

This class includes manufacture of machines for additive manufacturing by metal deposit, plastics or rubber deposit, plaster, cement, ceramics or glass deposit and other.Additive manufacturing means the formation of physical objects, based on a digital model, by the successive addition and layering, and consolidation and solidification, of material.

28.49 Manufacture of other machine toolsThis class excludes manufacture of additive technology machines (28.42)

Countries in favour of this proposal: Poland, Italy, Germany, Finland, Greece, Austria, Lithuania, the Netherlands and Ireland.

-Proposal 2: Merging 28.41 and 28.49 and call the class Manufacture of metal machine tools (although removing the residual 28.49 may not be a good idea, considering the evolution in the sector. Countries in favour: Slovenia, Denmark, France, Sweden, Croatia and Switzerland.

Although a majority of countries was for proposal 1, before the TF takes a final decision, the machine tool sector association should be contacted.

Proposal 70PROPOSAL: 13. Code: 28.92 - Manufacture of machinery for mining, quarrying and

construction Proposal: Manufacture of snow groomers to be added. Submitted by: Italy Please provide your comment on this proposal:

Austria Austria agrees with the proposal, because these machines are important.


Denmark ok

Finland Finland agrees to add an explanatory note for inclusion of "manufacture of snow-ploughs and snow-blowers" to 28.92. In our current national extension of NACE "manufacture of snow-ploughs and snow-blowers (used for maintenance of public roads and buildings)" and "manufacture of ski-track machines" are already included.

France A snow groomer is a tracked vehicle equipped in front with a shovel (or dozer blade) and behind with a cutter (or roller). It is usually driven by diesel engines. When the machine drives over a snowfield, it pushes snow ahead of it and, at the same time, smooths out any surface unevenness. It is a specialized version of a snowmobile.

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_________________________________________________________________________________

France position : We agree with the proposal.

In France, we classify the manufacture of snowplow in « 28.92.30 Other excavating machinery » and we think the manufacture of snow groomers should also be classified in 28.92 (for CPA, we propose 28.92.23 Self-propelled tamping machines and road-rollers rather than 28.92.30 Other excavating machinery).

_________________________________________________________________________________

Notes : snowmobile are vehicles used for transport of passengers or goods, that is not the purpose of snow groomers so we exclude 29.10.52.

France already sent

Germany Agree


Hungary Hungary:

CPA 28.92.30 Other excavating machinery – CN 8430 20 00 Snowploughs and snowblowers (excl. those mounted on railway wagons, motor vehicle chassis or lorries)

PRODCOM:

28.92.30.30 Snow-ploughs and snow-blowers

I agree with the proposal. CN 8430 20 00 correspond to PRODCOM 28.92.30.30 Snow-ploughs and snow-blowers.

Italy Italy would like to add the manufacture of snow groomers to the explanatory notes of NACE class 28.92.

Lithuania We agree with the proposal.

Malta no comment

Netherlands No comment.

Poland We support Italy's proposal, adding in the explanatory notes NACE 28.92, that the class also includes the production of snow groomers. According to the explanatory notes in CN, track-lying tractors, with particularly wide tracks, for leveling and whipping snow on ski trails are covered by CN code 8701 30 00, linked to CPA 28.92.50.

We suggest adding in the explanatory notes "This class includes:" the

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following indent:

- production of snow groomers intended for leveling and whipping snow on ski trails

Slovenia Production of snow groomers should be mentioned in class NACE 28.99 Manufacture of other special-purpose machinery n.e.c.

They are not construction machines - they only prepare slopes for skiing.

They are classified in CPA 28.99.39 special-purpose machinery n.e.c.

Sweden Agree.

Switzerland The snow groomers are already classified in 29.10 (see explanatory notes: "This class includes:...- manufacture of other motor vehicles: - snowmobiles, golf carts, amphibious vehicles...")

United Kingdom NAICS include snow ploughs within 333120 (Construction Machinery Manufacturing) - correlation with NACE:

25.73 Manufacture of tools

28.22 Manufacture of lifting and handling equipment

28.24 Manufacture of power-driven hand tools

28.29 Manufacture of other general-purpose machinery n.e.c.

28.30 Manufacture of agricultural and forestry machinery

28.92 Manufacture of machinery for mining, quarrying and construction

RECOMMENDATION:Include manufacture of snow-groomers, snow-ploughs and snow-blowers in the explanatory notes of 28.92

Proposal 71PROPOSAL: 14. Code: 28.94 - Manufacture of machinery for textile, apparel and leather

production Proposal: According to Trade described CPA 28.94.40, sewing machines of the household type are linked to 46.43.11 Wholesale trade services of electrical household appliances, except radio, television and photographic goods; In NACE 46.43 is an exclude: wholesale of sewing machines, see 46.64. If there (in 46.64) are only the sewing machines, which are not of the household type, we should clarify this in the explanatory notes. Submitted by: Austria Please provide your comment on this proposal:

Austria Austria: The production of sewing machines of the household type is in 28.94, wholesale of sewing machines is in 46.64, but are in 46.64 sewing machines for households included?

Austria proposes to change explanatory notes of 46.43, that in 46.64 are

45

not sewing machines for households included.

Croatia We agree with the proposal, explanatory notes should be amended.

Denmark CPA 46.64.10 needs to be revised to include household sewing machines

Finland Finland agrees with the proposal to clarify the wholesale activity of sewing machines - whether both household and industrial types of machines are in Class 46.46 or not. A general remark is that the borderline of private and professional use (here household and industrial) has become somewhat blurred in recent years.

France _____________________________________________________________________

France proposal : add notes in NACE

46.43 Wholesale of electrical household appliances

This class includes : wholesale of sewing machines of household type

Or This class excludes: - wholesale of industrial sewing machines, see 46.64

46.64 Wholesale of machinery for the textile industry and of sewing and knitting machines.

This class includes : wholesale of industrial sewing machines

or This class excludes: - wholesale of sewing machines of household type, see 46.43

_______________________________________________________________________

France already sent

Germany Agree. Index entry "Sewing machines, electric, domestic, wholesale" was coded in ISIC Rev.3 in "Wholesale of other household goods" (5139"). In continuity of that logic we would also propose to explicitly exclude it from class 46.64 and explicitly include it in 46.43.

Greece we believe it is clear that the sewing machines of the household type are classified in class 46.43 and the sewing machines which are not of the household type are classified in class 46.64 but if you believe that we should mention it in the explanatory notes we don't have objection.

Hungary Hungary:

This proposal refer to 46 and not 28. Please remove it from 28 to 46.

I agree with the proposal. We would modified the explanatory notes of 46.43 and 46.64 as follows:

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46.43 Wholesale of electrical household appliances

This class includes:

- whole sale of sewing machine of household type

This class excludes:

- wholesale of sewing machines other than household-type, see 46.64

46.64 Wholesale of machinery for the textile industry and of sewing and knitting machines


- wholesale of sewing machines household-type, see 46.43

Italy Italy agrees with Austria on the need to clarify: NACE class 46.43 includes sewing machines of the household type while NACE class 46.64 includes sewing machines for the textile industries, so exclusions should be added.


Malta no comment

Netherlands Agree.

Poland We support Austria's proposal.

Additionally, we propose to add in the explanatory notes of 46.43:

1) the class includes wholesale of household sewing machines,

and complete the existing notation, that

2) the class does not include the wholesale of industrial sewing machines classified in NACE 46.64.

To the explanatory notes of 46.64 class add:

1) the class includes wholesale of industrial sewing machines

Slovenia In NACE 46.43, we delete the exclusion - wholesale of sewing machines, see 46.64.

We also support the clarification in the explanatory notes.

Sweden Agree, clarify in the explanatory notes.

Switzerland Agree, with this comment.


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AT: No new class.DK: support and recommend changes in CPA

RECOMMENDATION:The explanatory notes of 46.43 and 46.64 will be amended as follows:46.43 Wholesale of electrical household appliances This class includes:

- whole sale of sewing machine of household typeThis class excludes:- wholesale of sewing machines other than household-type, see 46.64

46.64 Wholesale of machinery for the textile industry and of sewing and knitting machines This class excludes:- wholesale of sewing machines household-type, see 46.43

Proposal 72PROPOSAL: 15. Code: 28.99 - Manufacture of other special-purpose machinery n.e.c.

Proposal: The manufacture of automatic bowling alley equipment (e.g. pin-setters) is explicitly mentioned in the explanatory notes of NACE 28.99. But PRODCOM List includes this product in 32.40 (32.40.42.70). In the correspondence table CN 9504 90 80 has a link to CPA 32.40.42. We suggest to move the manufacture of automatic bowling alley equipment (e.g. pinsetters) from 28.99 to 32.40. Reasoning: this equipment can be used for automatic bowling only. Submitted by: Hungary Please provide your comment on this proposal:

Austria Austria agrees to the change in order to avoid in inconsistences.

Croatia We agree with the proposal to move the manufacture of automatic bowling alley from 28.99 to 32.40.

Denmark Disagree. Suggest revising the links instead.

Finland Finland agrees to move manufacture of automatic bowling alley equipment (e.g. pinsetters) from 28.99 to 32.40.

France Please provide your comment on this proposal :

It seems the code product has often changed in Prodcom. Right now it is classified in 32.40.42.70.

For reason of stability, the classification should be definitely stabilised.

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__________________________________________________________________________________

France position : An automatic bowling alley equipment is an equipment, so according to NACE criteria, it should be classified in division 28 Manufacture of machinery and equipment n.e.c. Ths equipment is a special-purpose machinery or equipment (so we can exclude 28.1 and 28.2). In other classes of division 28, only 28.99 can correspond as precised in NACE notes in division 28.

There is no activity or product in 32.40 that refer to an equipment.

We would prefer to keep this activity in 28.99, but whatever the choice will be, it has to be consistent with CPA-CN correspondance table and taken into account by Prodcom (It has to be stabilised once and for all).

__________________________________________________________________________________

Our yearly production team is in favor of maintaining in 32.40 but only because there is a need to stabilise the classification definitively.

NACE notes (division 28) indicate : « This division includes the manufacture of machinery and equipment that act independently on materials either mechanically or thermally or perform operations on materials (such as handling, spraying, weighing or packing), including their mechanical components that produce and apply force, and any specially manufactured primary parts. This includes the manufacture of fixed and mobile or hand-held devices, regardless of whether they are designed for industrial, building and civil engineering, agricultural or home use. The manufacture of special equipment for passenger or freight transport within demarcated premises also belongs within this division.

This division distinguishes between the manufacture of special-purpose machinery, i.e. machinery for exclusive use in a NACE industry or a small cluster of NACE industries, and general-purpose machinery, i.e. machinery that is being used in a wide range of NACE industries.

This division also includes the manufacture of other special-purpose machinery, not covered elsewhere in the classification, whether or not used in a manufacturing process, such as fairground amusement equipment, automatic bowling alley equipment, etc.

This division excludes the manufacture of metal products for general use (division 25), associated control devices, computer equipment, measurement and testing equipment, electricity distribution and control apparatus (divisions 26 and 27) and general-purpose motor vehicles (divisions 29 and 30).

France already sent

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Germany Agree. That is correspondig aslo to the perspective of CN.



Italy Italy is not in favor of the proposal to move contents; Italy proposes to change just the correspondence. It is true that NACE class 32.40 aggregates enterprises which have different features, for example the largest ones produce billiards but an automatic bowling alley equipment (e. g. pin-setters) is characterized by a “strong” mechanic part which is distinctive of NACE division 28. If we decide to move the automatic bowling alley equipment (e. g. pin-setters) we have to move also the “manufacture of roundabouts, swings, shooting galleries and other fairground amusements”.

Lithuania We agree this should be harmonized, but also about tanning beds, according Prodcom Tannig beds should be in NACE 27.90 class not in 28.99

Malta no comment

Netherlands I do not agree. Bowling alley equipment is not games or toys, this should stay in 28.99

Poland We support Hungary's proposal. We propose to remove the reference to the production of automatic bowling equipment from the explanatory notes in 28.99 NACE. In our opinion, not every type of product must be listed somewhere in NACE. The number of producers with automatic bowling as a main product is probably limited. The latest available data from PRODCOM statistics (reference year 2017) show that the product 32.40.42.70, which includes, inter alia, this type of equipment, represents about 2% of the value of EU 28 products in the range of 32.40; within 28.99 it will be 0.3%. If the explanatory note will not be completely removed, we support the proposal of moving it to 32.40.

Slovenia We agree with the proposal.

Sweden Is it the link between PRODCOM, CN and CPA that is faulty? CPA 32.40.42 says (excl. of bowling allery equipment). We don’t believe a pin-setter is an article but a machine/equipment.

Switzerland We think the current calssification is correct.

United Kingdom NAICS include this activity within 339920 Sporting and Athletic Goods Manufacturing.

Correlation NAICS 2017 – ISIC Rev 4:

339920 Sporting and Athletic Goods Manufacturing * 2829 Manufacture of other special-purpose machinery bowling alley equipment (pin setters and ball return equipment)

Suggest bowling alley equipment stays in div 28 in line with ISIC

PL: Creating a separate CPA subclass for a niche product would be irrational. It would be best to

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remove the note about "automatic bowling alley equipment" from the explanatory notes to NACE, because the products that constitute "automatic bowling alley equipment" have a different character and some are difficult to call machines, e.g. "automatic soccer" - this is a "computerized scoring system" detects pins "by electronic means, processing and visualizing the state of the game. And many of the equipment is specialized furniture.HU: We think, we should create a new CPA item (28.99.33 OK) because it's very different from other machines / equipment.

RECOMMENDATION:Manufacture of automatic bowling alley equipment (e.g. pinsetters) remains in 28.99. As the production is apparently very small it could be included in CPA 28.99.39

Proposal 73PROPOSAL: 16. Code: 30.1 - Building of ships and boats Proposal: Combine

shipbuilding repair (33.15) with shipbuilding (30.1). Repair is not a single industry - separating the repair form the manufacture doesn’t allow for the industry as a whole to be measured. Submitted by: United Kingdom Please provide your comment on this proposal:

Austria Austria: If we kill 33.15, we have to kill 33.16 and do the same in ISIC (3315). This is the main problem of division 33. If we do this, we have to restructure division 33.

Austria is in favour of restructuring division 33.

Croatia We consulted our industry department and their position is to leave separate class for ship repairing. On the other hand, some other activity classifications have only one class for shipbuilding and repairing (NAICS, ANZIC), also one class for railway rolling stock manufacturing and repair services and aircraft manufacturing and repair services (ANZIC).

Denmark agree - distribute 33.15 between 30.11 and 30.12 - but only if a proper revision is necessary

Finland Finland has no position.

France Notes : is it shipbuilding repair or is it substantial alteration, renovation or reconstruction of ships ? In the second case, the activity is classified in 30.1 and maybe we could add the activity in NACE notes of 30.11

____________________________________________________________________________________

France position : we disagree with the proposal.

NACE criteria is to split activity of manufacture and service of repair. So we disagree with this proposal.

If a unit carries out both activity, top-down method should be applied.

_________________________________________________________________________________

France already sent

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Germany For consistency reasons we would prefer in that case to proceed for all other transport equipment equivalently.

Greece we disagree because if we unify the activity of manufacture and the activity of repair for ships and boats we should also do the same for other classes of division 33 such us the repair of trains or airplanes.

Hungary Hungary: Why should we come back to the previous version of the classification? (NACE Rev. 1.1: 35.1 Building and repairing of ships and boats). We don’t agree with the proposal.

Italy The proposal of Italian national association UCINA (https://ucina.net/) is to create a new class (e.g. NACE 30.13) within NACE group 30.1; in order to have a better correspondence of this activity to the related manufacture sector, the current NACE code 33.15 should be relocated within “Code 30.1 - Building of ships and boats” as a separate 4-digit NACE code (e.g. 30.13).

Lithuania We do not agree with the proposal. It should be separated, but with the manufacture and repair of ships there is always some difficulties. Could be the explanatory notes of both classes supplemented, especially where should be the installation of equipment and ships completion and finishing.

Malta Disagree. The manufacturing process should be up to completion of the Fixed Asset, whereas NACE 33 should be related to repair and routine maintenance.

Netherlands Not in agreement. Repair for all sorts of activities is currently grouped under 33. It should remain under 33.

Poland We do not support the UK proposal.

Group 30.1 includes services related to the factory conversion and reconstruction of ships and other floating constructions (eg. CPA 30.11.91). This type of work is mainly carried out by shipyards.

In class 33.15 Repair and maintenance services of ships and boats are included specialized repairs and maintenance of ships and boats, carried out by various companies (including shipyards), providing such services on request. We have a large number of companies which only deal with ship repairs, not shipbuilding.

Slovenia It is not relevant for our country.

Sweden If the enterprise repair ships they themselves have manufactured then this should be included in the manufacturing code 30.1. If they repair ships on a fee or contract basis, this would be classified in 33.15. The proposal will have the effect of making repair of ships on a fee or contract basis into manufacturing of the whole ship.

Switzerland Strongly agree, repair should integrate into all divisions and not be a division on its own.


RECOMMENDATION:

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A majority of countries disagree with the proposal and prefer to have repair and manufacturing separated.

Proposal 74PROPOSAL: 17. Code: 30.30 - Manufacture of air and spacecraft and related machinery

Proposal: Drone - An unmanned aerial vehicle could be separated from manned aerial vehicles or the class 30.30 should be revised and drones included in explanatory notes. Drone companies from around the globe are designing and building these machines these days, from foam toys to high-grade materials in professional gear. The list of the companies and their products would be really huge, shouldn‘t we take this into consideration? Submitted by: Lithuania Please provide your comment on this proposal:

Austria Austria supports to include the production of drones in explanatory notes in 30.30 (but the definition must be correct, because some drones are in 32.40).

Croatia We definitely need to include manufacturing of drones in explanatory notes. The question is whether we will make a difference between drones (professional, with camera, toys….). In our opinion, it is not necessary to separate unmanned aerial vehicle from manned aerial vehicles.

Denmark Revise notes

Finland Finland agrees with the proposal to make manufacture of drones visible in NACE, either adding an inclusion to explanatory notes of revised Class 30.30 or separate to an own new class. However, it is important to take into account the multifaceted nature of drones: for photographing and filming, for transporting; or as toys, weapons, …

France A drone is an unmanned aerial vehicle (UAV) (or unscrewed aerial vehicle). It is an aircraft without a human pilot on board. UAVs are a component of an unmanned aircraft system (UAS); which include a UAV, a ground-based controller, and a system of communications between the two. The flight of UAVs may operate with various degrees of autonomy: either under remote control by a human operator or autonomously by on-board computers.

Warning : The use of the word "drone" to describe a vehicle or robot on land, on the surface or underwater, with autonomy, is a French particularity. The American classification of autonomous non-human mobiles on board in UAV/UAS (air), USV/USS (surface), UUV/UUS (submarines), UGV/UGS (land robots) is the most commonly used in the world.

_____________________________________________________________________________________

France position :

- In France, we use the word drone to describe not only an aerial vehicle

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but also a vehicle or robot on land, on the surface or underwater. Are we the only one to do that ? We would prefer not to use the word drone or to define clearly the word if it used in NACE to avoid misunderstanding by French users.

- Classify the manufacture of aerial drones in 30.30 (even used for recreational purpose)

> add an exclusion note to 32.40

> add notes to NACE 30.30 (aerial drones)

- Create a specific CPA in 30.30 when there’s no human driver in the equipment.

_______________________________________________________________________________________

France already sent

Germany Correspondingly to CN drones should be mentioned with and according to their special characteristics in classes 26.40 (with video camera), 26.70 (with camera), 30.30 (large ones as specified in CN) or 32.40 (small ones as specified in CN).

Greece we agree that the manufacture of drone should be included in the explanatory notes of class 30.30. But we are not sure if all kinds of drones are classified in this class. ex. drones with digital camera or video camera, small drones for non-professional use (as toy).

Hungary Hungary: We agree with the proposal. Drones should be classified to 30.30; if it is a game: 32.40

Italy Italy is in favour of including all drones in NACE class 30.30 but toys which should be classified in NACE class 32.40 Manufacture of games and toys.

Lithuania Our proposal.

Malta Agree

Netherlands In agreement for inclusion under this code. Not a new code. In Dutch version drones are already mentioned.

Poland It seems reasonable to isolate the production of unmanned aerial vehicles.

In our opinion, unmanned aerial vehicles in armed forces and unmanned aerial vehicles used in: scientific research, search and rescue operations, forensics - should be classified in 30.30 NACE and such indent should be added to the explanations of this class.

However, unmanned aerial vehicles, usually purchased for entertainment or recreational purposes, for children and adults, with a video camera or digital camera, according to the decision of the Harmonized System Committee (HSC) of March 2015 - drones packed in sets for retail sale, containing a remotely controlled multirotor helicopter, also called the "quadcopter", with an integrated digital camera (dimensions: 29 cm x 29 cm x 18 cm, weight: 1160 grams) - CN 8525 80; CPA 26.30.13; 26.40.33, 26.70.13; NACE 26.30, 26.40 or 26.70, depending on the type of recording medium (video camera or digital camera).

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An unmanned helicopter / remotely controlled airplane, without a video camera or digital camera installed, should be treated as a toy and classified in NACE 32.40.

Is it possible to define unmanned aerial vehicles (drones), which are produced by aviation, toy or photographic industry? Defining production activities without defining its products is of little consequence.

Slovenia We agree with the proposal, that an unmanned aerial vehicle could be separated from manned aerial vehicles.

Sweden We do not think it is necessary to split manufacture of vehicles into manned and unmanned. If so we would have to create a class for all other sorts of unmanned vehicles such as cars, trucks and ships. Is this what we want?

Switzerland Drones must be integrated into the CPA, their usefulness must be distinguished according to economic activity.

As a general rule, the manufacture of drones must be in Division 26.

United Kingdom Agree, drones vary greatly in type and use, as such, further discussion is needed to agree suitable classification

HU: We agree that there may be multiple locations depending on the type and purpose of your drone.

RECOMMENDATION:Unmanned aerial vehicles are of many types from transporting passengers to small toys. They can also be used for military purposes. Some include cameras other not. The Task force thinks that more discussion is needed on this subject. It is expected that the production of these drones is expected to increase. This topic will be included in the forum for discussion.

Proposal 75PROPOSAL: 18. Code: 30.30 - Manufacture of air and spacecraft and related machinery

Proposal: Aerospace to have its own division (replacing existing class 30.30) and to be combined with the repair activities within 33.16 Division to include separate classes for: Defence Aerospace Manufacture (including repair) Civil Aerospace Manufacture (including repair) Spacecraft Manufacture (including repair) Aerospace is a growing industry in most developed economies and is very different from the other elements of “other transport” in terms of technology. Increasing demand for a split between civil and defence. Submitted by: United Kingdom Please provide your comment on this proposal:

Austria Austria is against this proposal, because this would bring empty classes, because this activity is not relevant for all countries in Europe. We can only change within the border of ISIC Rev.4.

Croatia In our opinion, it is not necessary to raise manufacture of air and spacecraft and related machinery to division level. Maybe we should

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consider combining manufacture of aircraft with repair activities.

Denmark Yes and no.

Yes, combine 30.30 with 33.16, but no division.

We suggest National subdivision, if necessary.


France Aerospace is a highly concentrated sector, to differenciate within this sector will bring problem of dissemination as there’s not enough firms in this sector.

_______________________________________________________________________________________

France position : We disagree with the proposal.

- CPA heading are sufficient to distinguish aerospace from spacecraft manufacture.

- activity of repair is not classified with manufacture according to NACE criteria (unless it is alteration, renovation or reconstruction activities).

________________________________________________________________________________________

France already sent

Germany Agree.

Greece we disagree because we believe that the manufacture of aerospace in Europe includes few industries.

Hungary Hungary: We don’t agree with the proposal. The manufacture and the repair activities are separated in Hungary.

Italy Italy has no stance on the proposal and is waiting for comments on behalf of national associations. However, there may be the risk of having empty classes and problems of data confidentiality.

Lithuania We agree that could be separate classes, but the separation between defence and civil not very good idea, if you can remember the history of GPS. The project was launched by the U.S. Department of Defence in 1973 for use by the United States military and became fully operational in 1995 and It was allowed for civilian use in the 1980s. We think the class could be separated to unmanned aerial vehicle and manned aerial vehicles and spacecrafts.

Malta Would a NACE group (rather than a new division) or class be enough (similar to the manner space travel is distinguished from air travel in NACE 51)? This split has to be further reflected in NACE 33.16

Netherlands Aerospace can constitute a new sub-code under 30. However repair

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activities should remain under 33, and could acquire a new sub-code in 33, consistent with the new sub-code under 30.

Poland We do not support the UK proposal.

According to CN, aircraft and spacecraft are classified in one CN code 8802.

The creation of separate classes for the production of aircraft in accordance with their use depends on the needs of research that are conducted in the statistics of each country and such a division could be provided at the national level. We recommend leaving 33.16 class in NACE. The proposed changes would have an impact on advanced technology statistics: 30.3 group was classified as technologically advanced and 33 as intermediate. The advanced level includes only two divisions (21 and 26) and 30.3 group, so it is sensitive to changes.

Slovenia We agree with the proposal although this is not relevant for our country.

Sweden Agree.

Switzerland The activity of reparation could be included in 30.30


RECOMMENDATION:The separation or merging of manufacture and repair was discussed on proposal 73. The separated identification of Aerospace raises the problem that this sector is concentrated in a very small number of countries and its identification in national classifications would be more appropriate.

Proposal 76PROPOSAL: 19. Code: 30.40 - Manufacture of military fighting vehicles Proposal:

Please add to the description of this class that repair and maintenance of such vehicles has to be classified into this class. Submitted by: Estonia Please provide your comment on this proposal:

Austria Austria disagrees with the proposal. In explanatory notes of NACE Rev.2 class 33.17 we have an exclusion to 30.40. So it is already mentioned.


Denmark agree


France In NACE, it is mentioned that repair and maintenance of military fighting vehicles in the exclusion of 33.17 Repair and maintenance of other transport equipment : « repair and maintenance of military fighting vehicles, see 30.40 »

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________________________________________________________________________________

France position :

Usually activities of repair are not classified with activities of manufacture. It seems to be an exception for manufacture of military fighting vehicles.

_________________________________________________________________________________

In French classification :

- repair and maintenance of military fighting vehicles is classified in division 33

- alteration, renovation or reconstruction activities are classified in 30.40

If we are wrong, we will change our national notes, otherwise we should mention this exception (if it is confirmed) in NACE notes.

________________________________________________________________________________

France proposal :

We would like also to add the mention « alteration, renovation or reconstruction activities of military fighting vehicles » in 30.40 and create a CPA for this activity or mention this activity in CPA notes.

__________________________________________________________________________________

France already sent

Germany Agree.

Greece we agree

Hungary Hungary: We don’t agree with the proposal. We believe that the repair and maintenance of military floating vehicles should be mentioned under 33.17.

Italy Italy agrees on adding an inclusion to NACE class 30.40: repair and maintenance of military fighting vehicles is included in NACE class 30.40. Indeed, NACE class 33.17 already excludes this activity.


Malta Do not agree that (any) repair-explicit services are shifted away from NACE 33 and into manufacturing industries.

Netherlands Not in agreement. Repair activities should remain under 33.

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Poland We support Estonia's proposal to add an information in the explanatory notes, that 30.40 class includes also repair and maintenance of military combat vehicles.

Slovenia In our national classification, we already have a comment in the subclass 30.400: "This includes:

- repair and maintenance of combat vehicles."

Sweden Agree. If the enterprises repair vehicles they themselves have manufactured. Repair on a fee or a contract basis would however be classified into 33.

Switzerland The activity of reparation could also be included in 30.40.

There should be some logic in determining when repair is an integral part of production.


FR: We would like to discuss the classification of repair and maintenance of military fightng vehicles in 30.40

We understand that it is very peculiar vehicles and that could explain the choice to classify manufacture and repair in the same class.

But, in parallel, manufacture of warships is classified in 30.11 and the repair is classified in 33.15

manufacture of airplanes for use by the defense forces is classified in 30.30 and the repair is classified in 33.16Why having a difference in NACE ?

RECOMMENDATION:Although we don’t know the historical reasons for the exception to the rule, but it doesn’t harm to include an inclusion to NACE class 30.40: repair and maintenance of military fighting vehicles. Repair on a fee or a contract basis would however be classified into 33.Ralf Becker will be contacted to try to understand the reason for this exception to the rule.

Proposal 77PROPOSAL: 20. Code: 31 - Manufacture of furniture Proposal: There is supposed to be

one of the strongest inconsistencies among all divisions in NACE Rev. 2 between the current structure of classes within division 31 and the product classifications (CPA and CN). Whereas ISIC Rev.4 does not split this division at all, NACE Rev. 2 is splitting according to end use of furniture but CPA and CN consider material of furniture. The approach should be reviewed. Submitted by: Germany Please provide your comment on this proposal:

Austria This is a big change, Austria supports the proposal to change the structure of manufacture of furniture in order to have no inconsistences between NACE Rev.2 and product classifications. ISIC Rev.4 does not split, so it

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would be no problem of inconsistence with ISIC Rev.4.

Croatia We agree, the approach should be reviewed. Link CPA – NACE should be considered to harmonise the structure between classifications.

Denmark Nace classifies activities whereas CPA and CN classify products, so there's bound to be differences. We do not know the reason for the split, but there must have been one. We have no issue merging the four classes into one. The activity is biggest for 31.09, but the turnover or employment in this division doesn't support a split.

Finland We treated questions 20 and 21 together.

Finland agrees that the structures of NACE and CPA are not consistent for Division 31. However, we do not identify any major problem in practice caused by the inconsistency.

Eurostat could verify the current size of the classes within Division 31 from SBS data. Maybe some aggregation rather than splitting could be done.

From the NACE point of view the double-titles of CPA are especially confusing: 31.0 Furniture and 31.00 Seats and parts thereof; parts of furniture.

France

___________________________________________________________________________

France position :

We would prefer to avoid the CPA headings in 31.00.xx that are not imbricated in NACE.

We propose :

- to create a new class in NACE for « Seats and parts thereof »

- and we will have to decide what to do with parts of furniture 31.00.20 Parts of furniture (except seats)

___________________________________________________________________________

We think it could be a good idea to modify NACE class for division 31 Manufacture of furniture.

The criteria of classification are not clear :

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What is the most important ?

--------------------- final purpose : seems to be the room (or the place/client) where the furniture will be used :

First, what is a kitchen chair ? Firms don’t know the definition of kitchen chair.

Today the tastes in decoration have changed. The kitchen chairs are not only made of wood but also of plastic and metal, like other furnitures for kitchen.

If we consider the final purpose (room, place or clients) : It is not really pertinent for some furniture :

Of course, a mattress is special case. But a bookcase for household is the same as a bookcase for firms. same for a seat in metal for the kitchen or for an office, the choice doesn’t seem useful and operational.

Destination should not be a criteria in division 31.

If it is the same intrant, same process, same product, it should be classified in the same class.

We think that the current breakdown of division 31 is maybe a legacy of a nomenclature that seeks to classify units and not activities. Usually, the firms that manufacture furnitures for offices and shops are specilized only in "manufacturing furnitures for offices and shops". It doesn't mean it is a unique activity in regard to NACE. Manufacturing a chair for a restaurant, a desk, a bookcase can't be considered as the same activity under the pretext that they are intended for offices or shops.

--------------------- or the materials used to manufacture ?

It seems to be more logical, the problem will come from multi-material furnitures.

______________________________________________________________________________

France alternative proposal :

We propose to change the structure of division 31 as below :

31.1 Seating furniture (and parts thereof)

31.11 Seats and armchairs (and parts thereof)

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---------------- - Swivelling and adjustable

---------------- - Others with wooden frames

---------------- - Others with metal frames

---------------- - Others with frames made of other materials

---------------- - Parts of seats

---------------- - Partial or subcontracted operations

31.12 Couches, sofas convertible or not (and parts thereof)

---------------- - Wooden frame, textile cladding

---------------- - Wooden frame, leather upholstery

---------------- - Other materials?

---------------- - Parts of seats


31.2 Seat upholstery


31.3 Mattresses and Box Springs (and parts thereof)

31.30 Mattresses and Box Springs

---------------- - 31.03.11 Bases

---------------- - 31.03.12 Mattresses


31.4 Other furnitures (and parts thereof)

31.41 Other furnitures in wood (and parts thereof)

To see what is favoured as a criterion beyond the material:

- shape (table, bed, wardrobe/buffet, etc.)

- destination (furniture that is furnished as opposed to furniture related to an activity (craft furniture, drawing table, logs, etc.)

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31.42 Other furnitures in metal (and parts thereof)




31.43 Other furnitures in plastics (and parts thereof)




31.44 other furnitures in other materials (bamboo, rattan,cardboard...) (and parts thereof)




31.5 Furniture finishing services (excluding seat upholstery)


___________________________________________________________________

France already sent

Germany Agree.

Greece we disagree, we would like to keep the splitting according to end use of furniture as discribe Nace Rev2.

Hungary Hungary: We agree with the proposal. We classify statistical units (enterprises) into NACE classes, so we have to take into consideration how the enterprises are specializied in furniture industry? According to the material of furniture (wood, metal, plastict etc) or end use of furniture (office furnniture, living room furniture etc). We should ask the opinion and proposal from association of furniture industry.

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Italy Until now Italy has not received any proposals from sectoral experts for the modification or improvement of the content of NACE division 31. Assilea, the national Italian leasing association (https://www.assilea.it/) considers it useful to have a NACE classification split according to the end use of furniture in order to distinguish the different investment expenditures.

Lithuania We do not agree to split furniture by material.

Malta Agree with proposal pushing for harmonization between NACE and CPA.

Netherlands Not in agreement. Multiple materials could be used in the end-product, this means companies would have to split their responses accordingly.

Poland We support Germany's proposals. The NACE and CPA structures should be consistent at the class level.

Slovenia We agree with the proposal that we should harmonize NACE, CPA and CN classifications.

Sweden Agree.

Switzerland Completely agree.

It is difficult to distinguish where to classify the manufacture of wooden furniture, 16 or 31?

16 - Approach by material

31- Approach by product


PL: The structure of NACE and CPA should be agreed. Isolating the seating furniture class, as in the CPA, seems to be the right approach (there is no such class in NACE. You can consider creating a separate class for the production of parts for all types of furniture in Division 31, however it would require a change in the CPA (parts of different furniture are classifies in one class in CPA together with seating furniture).

AT: We are infavour of one class for all furniture as in ISIC, this would solve many problems and many enterprises produce furniture for multipurpose use and of many materials.

HU: Aggregate all manufacture of furniture in a single NACE class (consistency with ISIC)

RECOMMENDATION:The opinions are very divided.

- Keep present breakdown (but how to solve CPA inconsistency)- Aggregate all manufacture of furniture in a single NACE class (consistency with

ISIC)- French proposal

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- Align NACE structure with CPAIt was agreed to consult the federation on this issue

Proposal 78PROPOSAL: 21. Code: 31 - Manufacture of furniture Proposal: We propose to

harmonise the structure at 4 digit level of CPA with that of NACE. Reasoning: CPA 31.00 “Seats and parts thereof; parts of furniture” is one of the exceptions in the conformity of CPA to NACE. This deviation in 31 division causes many problem in statistical data processing, e.g. in calculation of the indicators of furniture industry, in industrial product statistics (PRODCOM), in calculation of principal activity of businesses etc. Submitted by: Hungary Please provide your comment on this proposal:

Austria Austria: Same as Proposal 20.

Croatia We agree, the approach should be reviewed. Link CPA – NACE should be considered to harmonise the structure between classifications.

Denmark See our comment to the German proposal.

Finland We treated questions 20 and 21 together.

Finland agrees that the structures of NACE and CPA are not consistent for Division 31. However, we do not identify any major problem in practice caused by the inconsistency.

Eurostat could verify the current size of the classes within Division 31 from SBS data. Maybe some aggregation rather than splitting could be done.

From the NACE point of view the double-titles of CPA are especially confusing: 31.0 Furniture and 31.00 Seats and parts thereof; parts of furniture.

France see proposal 20

___________________________________________________________________________

France position :

We would prefer to avoid the CPA headings in 31.00.xx that are not imbricated in NACE.

We propose :

- to create a new class in NACE for « Seats and parts thereof »

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- and we will have to decide what to do with parts of furniture 31.00.20 Parts of furniture (except seats)

___________________________________________________________________________

We think it could be a good idea to modify NACE class for division 31 Manufacture of furniture.

The criteria of classification are not clear :

What is the most important ?

--------------------- final purpose : seems to be the room (or the place/client) where the furniture will be used :

First, what is a kitchen chair ? Firms don’t know the definition of kitchen chair.

Today the tastes in decoration have changed. The kitchen chairs are not only made of wood but also of plastic and metal, like other furnitures for kitchen.

If we consider the final purpose (room, place or clients) : It is not really pertinent for some furniture :

Of course, a mattress is special case. But a bookcase for household is the same as a bookcase for firms. same for a seat in metal for the kitchen or for an office, the choice doesn’t seem useful and operational.

Destination should not be a criteria in division 31.

If it is the same intrant, same process, same product, it should be classified in the same class.

We think that the current breakdown of division 31 is maybe a legacy of a nomenclature that seeks to classify units and not activities. Usually, the firms that manufacture furnitures for offices and shops are specilized only in "manufacturing furnitures for offices and shops". It doesn't mean it is a unique activity in regard to NACE. Manufacturing a chair for a restaurant, a desk, a bookcase can't be considered as the same activity under the pretext that they are intended for offices or shops.

--------------------- or the materials used to manufacture ?

It seems to be more logical, the problem will come from multi-material furnitures.

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______________________________________________________________________________

France alternative proposal :

We propose to change the structure of division 31 as below (it is just a proposition) :







---------------- - Parts of seats


31.12 Couches, sofas, convertible or not (and parts thereof)




---------------- - Parts of seats






---------------- - 31.03.11 Bases

---------------- - 31.03.12 Mattresses

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31.43 Other furniture in plastics (and parts thereof)










France already sent

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Germany Agree.

Greece iif we want to harmonise Nace with CPA and PRODCOM we should review the division 31 of Nace Rev2.


Italy Until now Italy has not received any proposals from sectoral experts for the modification or improvement of the content of NACE division 31.

Lithuania We agree that this division could be arranged according CPA.

Malta Agree with proposal pushing for harmonization between NACE and CPA.

Netherlands Good to further look in to this.

Poland We support Hungary's proposals. The NACE and CPA structures should be consistent at the class level.

Slovenia We agree with the harmonization of classifications.

Sweden Agree.

Switzerland Agree. Same answer as question 20


PL: The structure of NACE and CPA should be agreed. Isolating the seating furniture class, as in the CPA, seems to be the right approach (there is no such class in NACE. You can consider creating a separate class for the production of parts for all types of furniture in Division 31, however it would require a change in the CPA (parts of different furniture are classifies in one class in CPA together with seating furniture).HU: Aggregate all manufacture of furniture in a single NACE class (consistency with ISIC)

RECOMMENDATION:Same issue as proposal 77.

Proposal 79PROPOSAL: 22. Code: 31.03 - Manufacture of mattresses Proposal: Add in the wording

the mention of the box springs. Submitted by: France Please provide your comment on this proposal:

Austria Austria agrees with the proposal to add box springs, because these mattresses are now very common.


Denmark Agree

Finland Finland agrees to add an explanatory note to Class 31.03 to include manufacture of box springs. The explanatory note already exists in our

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national extension.

France ________________________________________________________________________

France proposal :

Add « mattress supports » or « box spring » in NACE notes 31.03

It corresponds to CPA 31.03.11 Mattress supports.

______________________________________________________________________

France already sent

Germany It may be important in that case to have a clear borderline between box springs and box spring beds. Latter should be classified in 31.09.

Greece we agree


Italy Italy agrees on the proposal.

Lithuania We agree to supplement explanatory notes.

Malta no comment

Netherlands Is it not already mentioned: "mattresses fitted with springs"?

Poland In the explanatory notes of 31.03 class (2nd indent) there is the wording about the mattresses, could be added: mattresses with box springs.

(e.g. - production of mattress, including mattresses with box springs).

Slovenia We understand that box springs are a kind of mattress supports:

In the NACE class 31.03 it is already written: "This includes:

- manufacture of mattress supports ".

But yes, we can add in the wording the mention of the box springs.

Sweden Agreed. Also we would like to raise the question on how to class “continental-type” beds depending on if this is regarded as a mattress (31.03) or “other furniture” (31.09)?



PL: Continental type bed should be classified in 31.03

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FR: We would classify "continental bed" in 31.03 Manufacture of mattresses (if this class still exists after NACE revision).HU: add 31.03

RECOMMENDATION:Add an explanatory note to Class 31.03 to include manufacture of box springs.Continental type beds should be included in 31.03

Proposal 80PROPOSAL: 23. Code: 31.09 - Manufacture of other furniture Proposal: Individual

activities should be broken down into several codes. At the moment furniture includes bedroom furniture, living room furniture, seating furniture and garden furniture (31.09). While some other activities are broken down in great detail, in this case all furniture is broken down into four codes only. Submitted by: Slovenia Please provide your comment on this proposal:

Austria Austria: If furniture as whole will be changed (see proposal 20) then Austria agrees with this proposal, because NACE Rev. 2 class 31.09 now is a rest class with many different activities.

Croatia We agree with the proposal. Additionally, link CPA – NACE should be considered to harmonise the structure between classifications regarding division 31.

Denmark Disagree. If necessary, it can be solved with a National subdivision

Finland Finland disagrees with the proposal. One manufacturer typically produces furniture for various types of use. A finer break-down of Division 31 would lead to difficulties in classifying actors producing a variety of furniture.

France

see proposals 20 and 21

We don't want to maintain in NACE group the distinction "for household" and "for offices and shops".

A table for restaurant or a chair for a restaurant is the same as a chai or a table for households in terms of process.

________________________________________________________________________________

France proposal :

We propose to change the structure of division 31 as below (it is just a proposition) :

71







---------------- - Parts of seats


31.12 Couches, sofas, convertible or not (and parts thereof)




---------------- - Parts of seats






---------------- - 31.03.11 Bases

---------------- - 31.03.12 Mattresses





72







31.43 Other furnitures in plastics (and parts thereof)










France already sent

Germany It may be reasonable to differentiate between usual indoor furniture and special outdoor furniture. But that may also be to small-sized.

Greece we disagree to break down this class into several codes.

Hungary Hungary: We agree with the proposal. Accurate classification makes easier classifying production activities.

We would break down NACE 31.09 by raw material:

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- wood living room furniture, wooden bedroom furniture, wooden garden furniture and additional wood furniture

- metal ...

- artwork…

Italy Until now Italy has not received any proposals from sectoral experts for the modification or improvement of the content of NACE division 31.

Lithuania We agree that 31 division could be rearranged.

Malta no comments

Netherlands It is recommended for countries that need the specification do so in their country-specific NACE and aggregate data when needed for European statistic uses.

Poland We do not support Slovenia's proposal. The structure of Division 31 in NACE should be reviewed, but not necessarily more detailed by breaking down the previous class 31.09. The needs of product reporting are met by divisions in CPA and PRODCOM.

Slovenia This is our proposal.

Sweden Disagreee. We don't see the need for this to be broken down further.

Switzerland Look at the answer 20

United Kingdom There maybe difficulties in splitting these categories. for example, how would the production of living room furniture and conservatory furniture be split?

PL: The structure of NACE and CPA should be agreed. Isolating the seating furniture class, as in the CPA, seems to be the right approach (there is no such class in NACE. You can consider creating a separate class for the production of parts for all types of furniture in Division 31, however it would require a change in the CPA (parts of different furniture are classifies in one class in CPA together with seating furniture).

HU: Aggregate all manufacture of furniture in a single NACE class (consistency with ISIC)

RECOMMENDATION:Same issue as proposal 77.

Proposal 81PROPOSAL: 24. Code: 32.5 - Manufacture of medical and dental instruments and

supplies Proposal: NACE 32.5 should be distinguished at 2-digit. Submitted by: Malta Please provide your comment on this proposal:

Austria Austria is against this proposal, because it is too detailed at 2-digit level.

Croatia In our opinion, it is not necessary to raise manufacture of medical and

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dental instruments and supplies to division level, but could be split into several classes – medical and surgical/dental and orthodontics/ophthalmic goods.


Finland In principal, Finland agrees with the proposal to consider splitting GROUP 32.5 into more than one class. Currently, there is only one Class 32.50. However, Finland suggests a careful consideration on criteria for possible new classes under 32.5 as well as estimates of the respective sizes on European level.

We already have split 32.50 in our national extension into two classes:

- Manufacture of medical and dental instruments and supplies (excl. dentures)

- Manufacture of dentures, dental implants, etc.

France __________________________________________________________

France proposal :

Distinguish in 32.5 :

- manufacture of glass eyes

- other manufacture of medical and dental instruments and supplies (except. glass eyes)

_________________________________________________________

This distinction is already made in our national classification.

France already sent

Germany Agree. Due to the growing importance of medical products this seems to be reasonable.

Greece we disagree because we believe that 2 digit distinction is not necessary in the activity of this classification. Also if we break down this class what will happen to the classification of some products that are common?

Hungary Hungary: We don’t support the proposal.

Italy Since the last revision, Italian experts have not received any proposals to distinguish the manufacture of medical instruments and supplies from that of dental instruments and supplies at 2-digit level; the breakdown requested by Malta seems to be too detailed.

Lithuania We agree on the proposal. In Lithuania this is growing manufacture and if there is a need for more classes for medical equipment we think the proposal could be discussed.

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Malta Proposal 24: clarification that the distinction could be at class level.

Netherlands Not in agreement.

Poland We do not support this proposal. In our opinion, a 3-digit distinction is sufficient.

Slovenia We do not understand the proposal. We ask for a more detailed explanation.

Sweden Why? Needs more explanation.

Switzerland Do not agree. The actual distinction is ok.

The manufacture of medical equipment is located in the 26 and 32.

United Kingdom More detail would be welcome

PL: We reiterate our proposal that a further breakdown should be provided at national level and a 3-digit distinction is sufficient.HU: we still do not support the proposal. The actual distinction is ok, enough.

RECOMMENDATION:Proposal rejected. Although it is considered a growing industry, there is small support on having a division for Manufacture of medical and dental instruments and supplies. Some countries could be in favour of a further breakdown at class level but this would need further discussion as the proposals were quite different.

Proposal 82PROPOSAL: 25. Code: 32.50 - Manufacture of medical and dental instruments and

supplies Proposal: Currently in Class 46.43 (Wholesale of electrical household appliances), which includes wholesale of photographic and optical goods. However, corrective glasses or contact lenses prescribed by ophthalmologists are not strictly speaking present. In addition, the manufacture of spectacles is included in class 32.50 (Manufacture of medical and dental instruments and supplies). For example, wouldn't the wholesale trade in eyeglasses or corrective lenses be ultimately tied to class 46.46 (Cf product 46.46.12: Wholesale trade services of surgical, medical and orthopaedic instruments and devices), corrective lenses or lenses being manufactured on medical prescription? Submitted by: France Please provide your comment on this proposal:

Austria Austria agrees. Wholesale of eyeglasses and corrective lenses should be classified in 46.46.

Croatia We agree with the proposal. Should we do the same for retail trade (47.74)?

Denmark Agree. Wholesale of spectacles and such (from 32.50) should be moved to 46.46.

Finland Finland agrees that logically spectacles and contact lenses rather belong to "pharmaceutical goods" than "electrical household appliances". If there

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is a recommendation that wholesale of items manufactured within Class 32.50 should be in Class 46.46 then the proposed change should clearly be undertaken. On the contrary, we would not put any weight on who prescribes (or not) spectacles or contact lenses.

For our national extension we have already split Class 46.43:

- Wholesale of electrical household appliances

- Wholesale of radio and television goods

- Wholesale of photographic equipment and supplies

- Wholesale of optical good

For us it would be a minor change to move the already existing national class from under 46.43 to 46.46.

France Corrective glasses and contact lenses are ophtalmic goods used for health/medical purpose.

_______________________________________________________________________

France proposal :

- to add notes to class « 46.46 Wholesale of pharmaceutical goods »


• - wholesale of pharmaceutical and medical goods

• - wholesale of corrective glasses or contact lenses

- to improve the heading of class 46.46, e.g. « Wholesale of pharmaceutical and medical goods

- to assimilate sunglasses to corrective glasses and contact glasses for operational data collection purposes.

_________________________________________________________________________

France already sent

Germany Agree to shift wholesale with eyeglasses and corrective lenses to wholesale with medical goods due to similarity of markets and clients of wholesalers.

Greece we believe that the wholesale of corrective glasses or contact lenses

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prescribed by ophthalmologists are classified in class 46.43 and the manufacture of these eyeglasses in class 32.50. Also we think that there is not confusion between class 46.43 and 46.46. concerning eyeglasses. However we could in the class 46.43 add explanatory notes about the wholesale of corrective glasses or contact lenses prescribed by ophthalmologists.

Hungary Hungary: We agree with the proposal. TREDED repair is warranted.

Italy NACE class 46.43 contains “wholesale of photographic and optical goods”; however, the term “optical goods” seems too generic so it would be useful to add some explanations for example “wholesale of photographic and optical goods (lenses, optical microscopes, binoculars and telescopes)” all production activities included in NACE class 26.70. At the same time, explanatory notes to NACE class 46.46 “wholesale of pharmaceutical goods” should be enriched by adding eyeglasses or corrective lenses and all activities/products contained in NACE class 32.50 (ophthalmic goods, eyeglasses, sunglasses, lenses ground to prescription, contact lenses, safety goggles).

Lithuania We agree with the proposal, explanatory notes should be supplemented with corrective glasses or contact lenses.

Malta Agree to classify this activity in a separate class. The trade sector should include its sun/eye glasses class (which would include the sale of both eyeglasses and sunglasses) as in most countries we find a number of eyewear shops (preferably in the retail industry).

Netherlands Proposal or question is unclear. Code 32.50 states in the explanation “ manufacture of ophthalmic goods, eyeglasses, sunglasses, lenses ground to prescription, contact lenses, safety goggles”. Lenses are mentioned in this explanation.

Poland Spectacles and contact lenses are optical elements and wholesale trade with such products is classified in NACE 46.43 (CPA 46.43.14).

The sale of lenses prescribed by ophthalmologists and their adjustment to an individual recipient (services provided by opticians) is not classified in a wholesale trade, but in retail trade in NACE 47.78 (CPA 47.00.83). The optometrists' activity is described in the 2. indent in 47.78 NACE

Slovenia We agree with the proposal that the wholesale trade in eyeglasses or corrective lenses be ultimately tied to class 46.46.

Sweden Agree.

Switzerland It does indeed seem more consistent

United Kingdom Agree in principle, however contact lenses are also available without prescription and sometimes worn for cosmetic purposes, for example, coloured lenses and therefore warrants further discussion.

PL: We agree with the completion of explanatory notes in 46.46. We classify spectacles for a retail customer in 47.78, where the 'optics' section is listed. If we decide to use 47.74, this entry should be moved from 47.78 to 47.74

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HU: Heading of class 46.46 to be changed to Wholesale of pharmaceutical and medical goods - ok

Add the following text to the explanatory notes of 47.74:


- retail trade of corrective glasses or contact lenses

See explanatory notes of 47.78 NACE:- activities of opticians

you don't buy a separate lens, the optician makes it complete with the glasses

RECOMMENDATION:Add the following text to the explanatory notes of 46.46 :This class includes: • - wholesale of pharmaceutical and medical goods • - wholesale of corrective glasses or contact lenses, coloured lens and sunglasses

Heading of class 46.46 to be changed to Wholesale of pharmaceutical and medical goods

Add the following text to the explanatory notes of 47.74:This class includes: - retail trade of corrective glasses or contact lenses, coloured lens and sunglasses

Proposal 83PROPOSAL: 26. Code: 32.99 - Other manufacturing n.e.c. Proposal: In NACE 32.99 is

an "exclude" manufacture of work wear and service apparel (e.g. laboratory coats, work overalls, uniforms), see 14.12. In CN Explanatory Notes (Supplementary explanations) (ek62/2 = deutsche Version) is a note: Uniform and other similar official garments (judge's gowns, church vestments, for example) are not considered to be industrial and occupational garments. CN 6114 2 and 6114 3 and 6114 9 would therefore be linked to NACE 14.19. Submitted by: Austria Please provide your comment on this proposal:

Austria Austria proposes to change the exclusion to: (See 14.12, 14.19).

Croatia We think that professional uniforms should be classified in 14.12, sports uniforms in 14.19.

Denmark Why not 14.13 instead? Revise link.

Finland Finland has no position in the matter. However, if the note of exclusion in 32.99 is split into

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- Laboratory coats, work overalls, see 14.12

- Uniforms and other similar official garments (judge's gowns, church vestments), see 14.19

then the respective clarification should be added as an explanatory note to Class 14.19 as well.

France ______________________________________________________________________

France notes :

We have to define what a workwear and service apparel is for NACE.

_______________________________________________________________________

We currently define a workwear and service apparel in NACE by exclusion :

[14.12] This class excludes :

- manufacture of footwear, see 15.20

- manufacture of fire resistant and protective safety clothing, see 32.99

- repair of wearing apparel, see 95.29

[32.99] This class excludes :

- manufacture of workwear and service apparel (e.g. laboratory coats, work overalls, uniforms), see 14.12

So it seems that we consider uniforms as workwear and service apparel.

Next question : what is a uniform ?

Definition (dictionary) is : the distinctive clothing worn by members of the same organization or body or by children attending certain schools.

CN describes what could be considered as workwear and service apparel in 2 distinct parts :

6203 Men’s or boys’ suits, ensembles, jackets, blazers, trousers, bib and brace overalls, breeches and shorts (other than swimwear) ⇒ already taken into account in correspondence tables with CPA 14.12

6114 Other garments, knitted or crocheted ⇒ linked to 14.19

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CN 6114 notes are :

This heading covers knitted or crocheted garments which are not included more specifically in the preceding headings of this Chapter.

The heading includes, inter alia :

(1) Aprons, boiler suits (coveralls), smocks and other protective clothing of a kind worn by mechanics, factory workers, surgeons, etc.

(2) Clerical or ecclesiastical garments and vestments (e.g., monks’ habits, cassocks, copes, soutanes, surplices).

(3) Professional or scholastic gowns and robes.

Could products mentioned above (1), (2) and (3) be assimilated to work wear and service apparel ?

Perhaps we could use this revision of NACE to add terms to a glossary, where for example, we could define what a work wear and service apparel is for NACE. We don't think it is a good idea to define the content of NACE or CPA with correspondence table with CN. Correspondence tables are a tool that we can use but they can't be the source of our definition of an activity (NACE) or a product (CPA).

We should define table of correspondence from classification and not classification from table of correspondence.

So as precised above, we have to define what a work wear and service apparel is for NACE.

_______________________________________________________________________

France position :

- the manufacture of professional or scholastics gowns and robes, clerical garments or smocks and other protective clothing of a kind worn by mechanics, factory workers, surgeons should be classified in 14.12.

- NACE notes should be amended

- CPA notes should be amended (or maybe create new CPA)

- and table of correspondence CN-CPA should be amended too

Whatever the decision will be, these garments should be precised in NACE and CPA notes once and for all.

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______________________________________________________________________

France already sent

Germany We propose to solve the problem by secondary links between CN 6114 and NACE 14.12. Otherwise this quite special class only for manufacture of workwear would be shrinked too much.

Greece we believe that in class 32.99 is classified only the manufacture of fire fighting protection suits and the manufacture of fire resistant and protective safety clothing. All other manufactures of workwear and service apparel are classified in class 14.12. In the same class 14.12 we believe that they are classified also the uniform and other similar official garments.

Hungary Hungary: We agree with the proposal, it is necessary to correct the exclusion of 32.99. But we think that the manufacture of uniform should be classified into 14.13 like the normal wearing apparel. For example the wearing apparel of waiter, employees of a hotel, stewardess etc can be classified into 14.13 as suit, costume, skirt, blouse etc. The similar official garments (judge's gowns, church vestments) are very special, but they can be classified into 14.13, as well (as cape, cloak). So my proposal for the exclusion of 32.99:


- manufacture of workwear and service apparel (e.g. laboratory coats, work overalls), see 14.12

- manufacture of service apparel (e.g. uniforms, similar official garments), see 14.13

I don’t agree with classifying the uniform and similar official garments into 14.19 because 14.19 contains another types of wearing apparel e.g. babies' garments, tracksuits, ski suits, swimwear, manufacture of clothing accessories.

Italy It should be noted that the revision of the NACE classification will necessarily impact on the products classifications which will have to be modified and updated accordingly. In our opinion, uniforms and other similar official garments (judge's gowns, church vestments, for example) should be classified in NACE class 14.19 by adding an inclusion. According to the exclusion statement foreseen in NACE class 32.99 in Italy for NACE Rev.2 we decided to add uniforms and so on to class 14.12 but now we consider class 14.19 more appropriate.

In addition, it should be noted that the national association on textile SMI (https://www.sistemamodaitalia.com/it/#) proposes to create a new NACE class in division 14 for the manufacture of fire-resistant and protective safety clothing (now in NACE class 32.99).

Lithuania Judge's gowns, church vestments, police uniform - this is all workwear. But for example where to classify national clothes (costumes) and stage clothes, first model of the designer (artistic,original)?? We propose mention

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in 14.19 explanatory notes professional uniforms, but this could be challenge with the borderline with workwear. We also can consider to move all the professional uniforms, official garments etc. to 14.12 and change the name of the class "manufacture of workwear, uniforms and similar official garments".

Malta no comment

Netherlands Not clear what the proposal is. Please expand / explain.

Poland Production of workwear used at workstations, which is adapted to perform duties related to the profession (NACE 14.12 CN 6203, 6204, 6211) Protective safety clothing is clothing used to protect employees against hazards, which carry the work. These can be hazards of a thermal, mechanical, chemical, biological or atmospheric character - production of such clothing (NACE 32.99)

Uniforms and similar official clothing (for example, judge's gowns, church vestments) are not considered as workwear (Explanatory Notes of Combined Nomenclature, point 4) - NACE 14.19 (CPA 14.19.12, CN 6114)

We propose to add in the explanatory notes:

1) NACE 14.12, that the class also includes the production of lab coats and working overalls,

2) NACE 14.19, that the class includes the production of uniforms and similar official clothing (eg judge's gown, cassocks, habits, ecclesiastical vestments, etc.),

Also we propose to add in the explanatory notes:

1) NACE 32.99 does not include production of laboratory aprons and other workwear, classified in 14.12

2) NACE 32.99 excludes production of uniforms and similar official clothing (ex, judge's gown, cassocks, habits, church vestments etc.), classified in 14.19

cross out 32.99 - This subclass excludes - second indent

Slovenia We classify Judges' dresses and church suits in NACE 14.13; CPA 14.13.21 men or boys

CPA 14.13.31 women or girls.

Sweden Agree.

Switzerland Okay, but in Switzerland we are less concerned about the links between the different nomenclatures

United Kingdom UK support the inclusion of uniforms and the like within 14.12

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PL: We agree with the recommendations. Regardless of which decision is made, official clothing should be clearly identified in the explanatory notes of NACE, CPA and PRODCOM HU: Agree 14.12

RECOMMENDATION:Uniforms and similar official clothing (for example, judge's gowns, church vestments) should be considered as work wear and should be classified in 14.12. The links to CN and CPA should be corrected.

Proposal 84PROPOSAL: 27. Code: 32.99 - Other manufacturing n.e.c. Proposal: In NACE

manufacture of horse whips and riding crops is classified in class 15.12. CN 6602.00.00 Walking sticks, seat-sticks, whips, riding-crops and the like (excl. measure walking sticks, crutches, firearm-sticks and sports sticks) is linked to CPA 32.99.21. Submitted by: Austria Please provide your comment on this proposal:

Austria Austria proposes to move horse whips and riding crops to NACE Rev.2 class 32.99, or to change CN correspondence to CPA 2.1 class 15.12.

Croatia PRODCOM 15.12.11.10 includes riding whips and crops and 32.99.21.30 includes walking sticks, seat sticks and the like, but excludes whips and crops and their parts. Therefore, NACE 15.12 is correct class for manufacture of horse whips and riding crops.

Denmark Revise link.

Finland In survey 1 Q30 on Class 15.12 the final conclusion was given as "This class includes the manufacturing of very different articles that are manufactured using different technologies and materials. There is the feeling that this group should be revised but the Task force was not able to conclude."

Finland suggests that TF takes position to this proposal when revising Class 15.12 in more detail.

France Horse whips and riding crops are described in CN 6602 00 00 Walking-sticks, seat-sticks, whips, riding-crops and the like.

This group includes :

(1) Whips of all kinds generally consisting of combined stocks and lashes.

(2) Riding-crops consisting of stocks with, generally, a short leather loop in place of a lash.

In NACE, the manufacture of these products is classified in 15.12

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- manufacture of horse whips and riding crops

The current situation is correct and conform with ISIC 1512 Manufacture of luggage, handbags and the like, saddlery and harness

——manufacture of horse whips and riding crops

_____________________________________________________________________________

France position : In CN2019-CPA2.1 correspondence tables, CN 6602 is already linked to CPA :

- 32.99.21 Umbrellas and sun umbrellas; walking-sticks, seat-sticks and the like

- 15.12.11 Saddlery and harness for any animal, of any material

We could also add exclusion notes to CPA 32.99.21 for horse whips and riding crops (and with a link to 15.12.11)

__________________________________________________________________________________

France already sent

Germany We would assume that horse whips and riding crops are typical leather products whereas at least walking sticks are not so. Due to these inconsistent intensions of CN and NACE at that point we propose no change.

Greece we believe that the manufacture of horse whips and riding crops is classified in class 15.12. Also according the classification of CPA the subcategory 32.99.21 excludes the whips that classify them in class 15.12.11

Hungary Hungary: We agree with the proposal, it is neccessary to correct the correspondence table CN-CPA as follows:

CN 6602 00 00 – CPA 32.99.21

CN 6602 00 00 – CPA 15.12.11 (secondary link)

See the correspondence table CN-PRODCOM.

151211100 66020000 (32.99.21

151211100 42010000

151211100 66039090 (32.99.22

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NACE and PRODCOM are consistent. See the name of PRODCOM 15.12.11.10 „Saddlery and harness for any animal made from any material (including riding whips and crops and their parts, traces, leads, kneepads, muzzles, saddle cloths, dog coats)”

Italy Following NACE criteria, the manufacture of horse whips and riding crops are classified in class 15.12. The links with CPA and CN should be modified accordingly.

Lithuania Animal (horse) whips and riding crops should be in one class in 15.12.

But there are whips not for animals, where to classify them also in 15.12?

Malta no comment

Netherlands Not clear what the proposal is. Please expand / explain.

Poland We suggest leaving the classification unchanged. Both CPA 15.12.11 and CPA 32.99.21 are linked to CN 6602 00 00.

In the field of CPA 15.12.11 are saddlery and harness products (whips, horse picks), intended for animals. Therefore, their manufacture is in 15.12 NACE.

32.99.21 CPA includes sticks, hunting stools etc. In our opinion, their manufacture should remain in 32.99 NACE.

Slovenia Correct the CN code.

The whips should remain classified in NACE 15.12.

Sweden Agree, needs clarification.

Switzerland The problem is caused by the approach by material

United Kingdom Agree there is incongruence - Interestingly, subcategory 32.99.21 (Umbrellas and sun umbrellas; walking-sticks, seat-sticks and the like) excludes whips, cf 15.12.11

RECOMMENDATION:Manufacture of horse whips and riding crops remain classified in class 15.12Links with CN should be corrected:CN 6602 00 00 – CPA 32.99.21CN 6602 00 00 – CPA 15.12.11 (secondary link)

Proposal 85PROPOSAL: 28. Code: 32.99 - Other manufacturing n.e.c. Proposal: Protective safety

equipment should be separated. it looks strangely in the vicinity of earplugs or candles. This class includes too wide range of products. Protective safety equipment should be separated as their production process could

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be very specific and innovative with different high-tech technologies therefore comparing to the rest list of products in this class should be excluded. Submitted by: Lithuania Please provide your comment on this proposal:

Austria Austria disagrees because in CPA 32.99.11 are classified only protective gloves and safety headgear. Many other protective safety equipment is in other classes.

Croatia Class 32.99 should be split, so in principle, we support the proposal.


Finland In principal, Finland agrees with the proposal to separate manufacture of safety equipment from Class 32.99 to its own class. However, Finland suggests to first estimate the size of the proposed class on European level.

For our national extension we have already split Class 32.99 into two:

- Manufacture of safety equipment

- Other manufacture of products n.e.c.

France _______________________________________________________________________________

France position : Class 32.99 Other manufacturing n.e.c. includes many different activities.

In France, the manufacture of safety equipment represents a small proportion of the 32.99 (5%). At national level, these activities do not require the creation of a new class. Data about this new class « safety equipment » would not be disseminated in France (statistical secret). Information is already present in CPA.

However, if this is necessary at European level, we are not against a proposal. We will give our opinion after a proposal has been defined clearly.

_______________________________________________________________________________

France already sent

Germany In 2018 total production in EU28 of CPA 32.99.11 ("Safety headgear and other safety products") was 9% of 32.99. There are CPA subcategories in this residual class with even higher economic importance like 32.99.54 ("Candles, tapers and the like") with about 19%.

Greece we agree

Hungary Hungary: We agree with the proposal. Class 32.99 is too heterogeneous class, and enterprises specialize for the manufacture of different products. We propose to create separate class not only for protective safety products but a second class for pen, pencil, pencil lead, inked pad etc as well. In Hungary this latter production is significant and other enterprises specialize for it than the manufacture of candles, artificial flowers etc.

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Italy Italy agrees on the proposal to create a separate class for the manufacture of protective safety equipment. The national association on textile SMI (https://www.sistemamodaitalia.com/it/#) proposes to create a new NACE class in division 14 for the manufacture of fire-resistant and protective safety clothing (now in NACE class 32.99).

Lithuania Our proposal

Malta no comment

Netherlands Agreed as a new subclass (on national level), not a new class.

Poland We do not support this proposal.

Protective safety equipment classified in 32.99 is now separated at PRODCOM level under the code 32.99.11.30 (gloves etc.), 32.99.11.50 (headgear), 32.99.59.10 (gas masks without exchangeable filters, etc.). The total value of these products reported in the PRODCOM survey in 2017 in 28 EU countries represents only 2.3% of the total value of 32 Division. Creating a new, small class does not seem reasonable.

Slovenia Confidentiality issues in small countries if we exclude protective equipment from NACE 32.99.

Sweden Agree.

Switzerland That would seem too detailed.

We only classify economic activity. For example, if the production is electronic, it must be transferred to Division 26.

United Kingdom This has not been raised as a concern by UK, however it is apparent that the class includes a wide range of activities.

PL: There is no need to split the 32.99 class

AT: we propose a splitt in 1. writing material like pens, pencils, inked pads..2. candles and the like , 3. christmas products like artificial christmas trees and 4. Other

HU: we keep our opinion, stationery and stationery could be chosen separately.

RECOMMENDATION:Proposal rejected: Protective safety equipment was considered a too small industry to have a class.

Proposal 86PROPOSAL: 29. Code: 32.99 - Other manufacturing n.e.c. Proposal: The production of

burial coffins, now classified in NACE 32.99 should be classified in NACE 16.29 - Manufacture of other products of wood; manufacture of articles of cork, straw and plaiting. In accordance with international regulations for ecological and other reasons, coffins cannot be made from other materials

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such as wood. The production of coffins represents one of the major processors of timber in Slovenia. Submitted by: Slovenia Please provide your comment on this proposal:

Austria Austria agrees with the proposal to move the production of wooden burial coffins to NACE Rev.2 class 16.29, because they are wood products. But also to move the production of metal burial coffins to NACE Rev.2 class 25.99, because not all coffins are made of wood and therefore in NACE Rev.2 class 16.29.

Croatia Today we can also found producers of eco-coffins made of corrugated cardboard and innovative range of eco-coffins and urns that have been moulded from biodegradable, long fiber recycled paper (PULP).



France

_________________________________________________________________________________

France position :

We disagree with proposal.

In the end, a coffin is not only made of wood, it justifies the manufacture of such a product to be classified in 32.99 Other manufacturing n.e.c.

__________________________________________________________________________________

The coffin is the envelope, usually made of wood, in which the deceased is placed.

In France, it must include:

- 4 handles for carrying,

- A biodegradable bowl that lines the bottom of the coffin body and ensures its impermeability,

- A plaque bearing the deceased's first and last name, years of birth and death.

The other ornaments of the coffin are optional, at the discretion of the deceased's family:

- Capiton (mattress, coffin frame that covers the inner sides and body of the coffin, pillow and blanket)

- Additional handles,

- Screw cover,

- Religious or civil emblems: cross, crescent, star, pink...

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France already sent

Germany Agree, although this is a roll back again. CN 4421 99 91 ("Coffins of wood (excl. of fibreboard)") is also of wood and would better fit to 16.29. Anyway there do also exist coffins of other materials like tin coffins for transport purposes. Those have to be considered equivalently.

Greece we agree to classify the production of burial coffins in class 16.29 because the coffins are made of wood.

Hungary Hungary: We agree with the proposal, the burial coffin should be classified into NACE 16.29.

We also propose to split CPA 16.29.14 „Wooden frames for paintings, photographs, mirrors or similar objects and other articles of wood” into 2 separate subcategories as follows:

16.29.14 „Wooden frames for paintings, photographs, mirrors or similar objects (CN 4414 00 10 and 4414 00 90)

16.29.xx (new) Other articles of wood (CN 4421)

Otherwise CPA 16.29.14 will be too heterogenous.

Italy Italy agrees on moving the production of burial coffins to NACE class 16.29. Even if some burial coffins are galvanized, they are especially made by carpenters so they should be part of the wood industry.

Lithuania We don't agree.

Malta Agree - Should be made specific (explicitly) to wooden burial coffins.

Netherlands In theory this would be correct, although there might be countries where burial in other materials might still be legal. Code 16.10 refers mostly to primary wood processing into basic shapes. As the recoding would pose practical problems our proposal is to leave this activity in 32.99.

Poland We do not support Slovenia's proposal.

We propose to leave in 32.99 NACE the production of coffins without regard to the material from which they were made.. There are also coffins other than wood, for example: coffins made of metal for transporting corpses, ex. by airplanes. The correspondence tables between CN 2019-CPA 2.1 clearly link CN 4421 99 91 (wooden) coffins to CPA 32.99.59. In 2015, the PRODCOM nomenclature has been modified to include this link. Data regarding the production of wooden coffins are collected in the PRODCOM 32.99.59.90.

Slovenia This is our proposal.

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Sweden Agree.

Switzerland Agree, although some burial coffins are made of metal (very rare) .

United Kingdom This has not been raised as a concern by UK users

AT: Leave all coffins in 32.99.

HU: We agree. 32.99

RECOMMENDATION:Proposal rejected. Although most coffins are made from wood, they can be made made of many materials, including steel, fiberglass or recycled kraft paper. There is emerging interest in eco-friendly coffins made of purely natural materials such as bamboo, X-Board, willow or banana leaf.This would raise the problem of where to classify the manufacture of non-wood coffins. We would propose to leave them in 32.99.

Proposal 87PROPOSAL: 30. Code: 33.1 - Repair of fabricated metal products, machinery and

equipment Proposal: The activities below, relating to repairing, are primarily considered as service activities. These need to be shifted to the services domain. One to one correspondence needs to be retained, at least at 2-digit NACE. 33.1 - Repair of fabricated metal products, machinery and equipment 33.11 - Repair of fabricated metal products 33.12 - Repair of machinery 33.13 - Repair of electronic and optical equipment 33.14 - Repair of electrical equipment 33.15 - Repair and maintenance of ships and boats 33.16 - Repair and maintenance of aircraft and spacecraft 33.17 - Repair and maintenance of other transport equipment 33.19 - Repair of other equipment Submitted by: Malta Please provide your comment on this proposal:

Austria Austria does not know what exactly the proposal is. If the proposal is to restructure division 33 (see proposal 16), we agree to restructure division 33.

Croatia In our opinion repair of fabricated metal products, machinery and equipment should stay in manufacturing.

Denmark Disagree

Finland We did not quite grasp what exactly was proposed.

Finland wishes to highlight that the whole current group 33.1 is challenging to implement in practice. Enterprises typically do not offer repair and maintenance as their sole activity but rather as a support activity to the main activity.

France ___________________________________________________________

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________________

France position :

We disagree with the proposal. It has been a choice to distinguish repair of goods.

If we decided to change this rule (and we don’t want to change it) :

- we would also have to remove repair of cars from division 45.

- we would have to move the activities of installation too (33.1)

___________________________________________________________________________

NACE notes precise :

Repair, maintenance and installation services

In accordance with NACE Rev. 2, repair, maintenance and installation services are classified in division 33 for machinery and equipment, in division 43 for elements forming an integral part of a building or another construction object, in group 45.2 for motor vehicles and in division 95 for computers, personal and household goods.

Repair, maintenance and installation of machinery and equipment, which in the past was classified under manufacturing of the corresponding type of equipment, is now identified separately in division 33 (Repair and installation services of machinery and equipment). All specialised repair activities are isolated in CPA 2008.

This choice of classification is conform with ISIC :

135. ISIC, Rev.4 now provides separate categories for the repair of all kinds of goods. However, no single high-level category exists that would cover all repair activities.

Based on the type of good repaired, the activities are classified as follows :

• Repair of motor vehicles and of motorcycles are classified in classes 4520 and 4540, respectively.

• Repair of computers and communication equipment is classified in group 951.

• Repair of personal and household goods is classified in group 952.

• Repair of other machinery and equipment is classified in group 331.

• Repair of buildings and other structures is classified in division 43.

France already sent

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Germany Not agree. The borderline between repair and rebuilding is not very clear. Repair activities are also a kind of manufacturing activity, just not ending up with a new product.

Greece we disagree

Hungary Hungary: It is currently in the manufacturing industry because it is about repairing large machines that are used in industry, construction, mining, commerce etc. Improvement services for the population included in NACE 95 (except: 95.1, PC repair, used by businesses and the general public)

Italy Comment from the Italian national association UCINA (https://ucina.net/): “33.15 - Repair and maintenance of ships and boats” is an industrial activity and should not be shifted to the services domain. In order to have a better correspondence of this activity to the related manufacture sector, this code should be relocated within “Code 30.1 - Building of ships and boats” as a separate 4-digit NACE code (e.g. 30.13).

Lithuania We don't agree. This is industrial services, they should be in 33 division.

Malta Shifting Repair (NACE 33) to services is to reinforce the ties (harmonisation) between NACE and the BOP. In the new BOP manual (BPM6), repair will be classified as a service not as goods.

The rest of the industry (NACE 33.2 - installation) would remain in the manufacturing industry? Would it be logical for NACE 33.2 to be shifted to NACE F or also as services?

Netherlands Not recommended, leave all repair of machinery in one code (33).

Poland Please explain the proposal. We are not convinced that "change" is needed in this area. Division 33 includes only specialist repairs and maintenance of industrial machinery and equipment. Division 95 regards the repair of consumer products and those used as means of production and consumer goods.

Slovenia We disagree with the proposal.

The proposal should be harmonised with the ISIC classification.

Sweden Agree.

Switzerland These services will have to be integrated into the manufacturing subcategories.

United Kingdom Further details on this proposal would be welcome

RECOMMENDATION:Proposal refused. Repair was considered by a strong majority of countries to be part of manufacturing

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Proposal 88PROPOSAL: 31. Code: 35 - Electricity, gas, steam and air conditioning supply Proposal:

The European Union's Third Energy Package has led to a further unbundling of ownership of energy production and transmission facilities and in many cases to a split of ownership and operation of network infrastructure. Proposal of change: Creation of one or more categories for renting and leasing utility networks Submitted by: Germany Please provide your comment on this proposal:

Austria Austria agrees to create one new class, where only a few enterprises will be classified, but with high turnover. In general, division 35 should be discussed in the broadest sense, especially the treatment of class 35.14.

Croatia We need more information.

Denmark "Disagree. It is not relevant for DK. We do understand that the case in some countries is different from ours.

Don't the outsourcing rules cover this?"

Finland Finland has no position. Renting and leasing of utility networks is currently no major activity in Finland.

France The European Union's third energy package is a legislative package for an internal market for gas and electricity in the European Union. Its objective is to further open up the gas and electricity markets in the European Union. The package was proposed by the European Commission in September 2007 and adopted by the European Parliament and the Council of the European Union in July 2009. It entered into force on 3 September 2009.

The European Union's third energy package has led to greater ownership unbundling of energy production and transmission facilities and, in many cases, to the separation of the ownership and operation of network infrastructure.

The owner of the power distribution network can :

- Operate its electricity networks under direct control

- Entrusting your networks to an electricity concessionaire

- Give competence to an « Energy Syndicate» (The Energy Syndicate directly manages or delegates to a concessionaire the distribution of electricity)

In France, the municipalities own the low and medium voltage electricity distribution networks, as well as the low and medium pressure gas pipelines. The municipality therefore has the power to grant electricity and gas distribution, either directly or by delegating it to an inter-municipal syndicate (there are many syndicates, which can be created at the departmental level or group several municipalities with a total population of more than 1 million).

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In France, electricity and gas distribution is carried out under two regimes :

- In direct management by the licensor (municipality or syndicate)

- In a public service concession: the municipality or the syndicate delegates to a concessionaire the task of distributing electricity and/or gas on its territory.

A dedicated department is in charge of the INS of municipalities and public establishments such as syndicate of energy. They don’t collect data on this subject :

- either it’s a municipality and the main activity is classified in 84.11 (for a legal unit that also carried out other general public services) or 35.12 (for a local unit dedicated for this activity alone)

- or it is a syndicate of energy and, in this case, the syndicate never specify whether it operates directly or delegates to a concessionaire the distribution of electricity. The main activity is classified in 35.12 or 84.11 (if the syndicate consider carrying out only administrative activities).

____________________________________________________________________________

France position :

We're not sure that the renting and leasing of such facilities should be assimilated to division 35.

___________________________________________________________________________

France already sent

Germany Agree.

Greece we don't have comment.

Hungary Hungary: Not relevan is Hungary. But we agree with the proposal.

Italy More details on the proposal are needed. Assilea, the national Italian leasing association (https://www.assilea.it/), on behalf of Leaseurope, affirms that the market for the leasing of utilities distribution networks counts approximately 200 million euros per year in Europe for new transactions.

Lithuania If there is a need for such a class we don't mind.

Malta Agree

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Netherlands No comment

Poland We support Germany's proposal to create a new category for renting and leasing utility networks. We suggest to place it in the Division 35.


Sweden Ownership without operation, could this be included in 77? Operation of network could be included in 35.13?

Switzerland No opinion

United Kingdom Comment from Scottish Government (SG): As far as SG is aware there isn’t expected to be a substantial ‘leasing activity’. The initial point from Germany is correct that operating and ownership of electricity networks may be unbundled more over the coming years with one company building, owning and maintaining the infrastructure, another one in control of its operation (This is what has happened for the past 10 years in Scotland with SP Energy Networks and SSE Networks owning the electricity transmission networks, but National Grid operating it).However, there is no leasing involved in these arrangements

HU: Not relavant in Hungary.

it is worth setting up a special branch if there are companies that specialize in this and have a significant weight in the EU

RECOMMENDATION:Renting and leasing utility networks will be included in the explanatory notes of 35.14. Name of the class will be trade of electricity and Renting and leasing of electricity networks. The same should apply to class 35.23 Trade of gas through mains and renting and leasing of gas mains.

Proposal 89PROPOSAL: 32. Code: 35 - Electricity, gas, steam and air conditioning supply Proposal:

The production of electricity from renewable sources is increasing. It is necessary to separate this kind of activity and should be reflected in NACE. Submitted by: Lithuania Please provide your comment on this proposal:

Austria Austria agrees to separate the production of electricity from renewable sources. We propose to split the production of electricity to the sources, because the technology and the activity are different and we need information on the number of enterprises acting in this field.

Eurostat E2 We support this change, we proposed the same thing.

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.

Croatia We support the proposal; there should be distinction by the type of energy.

Denmark It is the same enterprises, apart from small communities that establish a local solution, so we suggest it solved with a National subdivision

Finland Finland supports this proposal and renewable energy production should have a separate class in NACE. Finland already has a separate 5-digit level class for renewable energy production and this class includes hydroelectric, wind power and photovoltaic. These 5-digit class is under the class 35.11.

There should be also separate classes for nuclear power and for energy production that is based on combustion of fuel. In Finland biofuels, peat, waste and fossil fuels are currently combusted mainly in same power plants and therefore it would be difficult to have a separate class for power plants that only combust biofuels even though it is considered to be renewable energy source.

France Same as proposal 33.

__________________________________________________________________________________

France position : We disagree with this proposal. There’s currently no dissemination of class 35.11 (statistical secret).

But we propose to make this distinction in CPA. Is it not sufficient ?

___________________________________________________________________________________

CPA 35.11.10 Electricity

This subcategory includes :

- electric energy, such as thermal, nuclear, gas turbine, diesel, hydroelectric and other renewable

France already sent

Germany Agree.

Greece we disagree. we believe that it is not necessary such a detailed break down of this class.

Hungary Hungary: We partly agree with the proposal. I would not split NACE 35.11 into to separate classes, because there are only a few producer in Hungary. But I would split CPA 35.11.10 into several separate subcategories, and create a new CPA subcategory for electricity produced from different sources.

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Italy Italy agrees on the fact that NACE should reflect the production of electricity from renewable sources. However, the extent of the details should be carefully planned in order to avoid empty classes and problems of confidentiality: would it be enough just to separate the production of electricity from non-renewable sources from the production of electricity from renewable sources?

Lithuania Our proposal

Malta Agree

Netherlands Yes, this is necessary, because the production structure of electricity production from renewable sources differs from that of coal and gas.

Poland We support Lithuania’s proposal to create a class in the production of electricity from renewable sources. We suggest to add it to Division 35

Slovenia In our national classification, we already have this kind of activity separately:

35.111 Electricity production in hydropower plants

35.112 Electricity production in thermal power plants, nuclear power plants

35.119 Other electricity production


- the production of electricity in power plants on the sun, wind, tide, etc.

- production of geothermal electricity

This does not include:

generation of electricity by incineration of waste, see 38.21

Sweden Agree.

Switzerland Shouldn't the distinction be made at the national level, we can improve the explanatory notes ? However, the notion of storage is missing.


PL: We agree with the recommendation that breakdown at the level of CPA is a better approach.

AT: the minimal approach can be a split of 35.11 in production of electricity from renewable sources and not from renewable sources in NACE.

HU: CPA breakdown is ok.

RECOMMENDATION:A big majority of countries are in favour of introducing the breakdown between the productions of electricity from renewable sources or not and there is a policy need for this information. 35.11 would be split into 2 classes:

- productions of electricity from renewable sources

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- productions of electricity from non-renewable sources

Proposal 90PROPOSAL: 33. Code: 35.1 - Electric power generation, transmission and distribution

Proposal: The classification of electrical energy production does not distinguish the type of energy: nuclear, photovoltaic, etc. Type of change: split. Submitted by: France Please provide your comment on this proposal:

Austria Austria agrees – see proposal 32.

Eurostat E2 In case a differentiation of electricity production taking into account the mode of electricity production (e.g. nuclear, etc.) we recommend to align it in some way with the approach in energy statistics

Croatia We support the proposal; there should be distinction by the type of energy.

Denmark Too many classes and too few enterprises, so not relevant for DK, therefor we suggest National subdivision.

Finland Finland supports the proposal of splitting Group 35.1 into more classes based on type of energy production.

For our national extension we have already split Class 35.11 into five national 5-digit classes:

- production of electricity with hydropower and wind power (photovoltaic and fuel cells included)

- separate production of electricity with thermal power (traditional power plants etc.)

- combined heat and power production

- production of electricity with nuclear power

- heat and power production for industry

We wonder whether other countries already divide Class 35.11 into similar national classes as we do? Maybe the proposed change is merely to bring the split to the European level from national levels?

Respectively, we suggest considering a similar split for Class 35.30 Steam and air conditioning supply:

- geothermal

- solar

- nuclear heat

We will include the proposal to the large consultation (due 30 Sep 2019).

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France Same as proposal 32.

_______________________________________________________________________________

France proposal : Even if it’s our proposal, we disagree with a modification of NACE. There’s currently no dissemination of class 35.11 (statistical secret).

But we propose to make this distinction in CPA. Is it not sufficient ?

_______________________________________________________________________________

CPA 35.11.10 Electricity

This subcategory includes :

- electric energy, such as thermal, nuclear, gas turbine, diesel, hydroelectric and other renewable

France already sent

Germany Agree.

Greece we disagree. we believe that it is not necessary such a detailed break down of this class.

Hungary Hungary: We partly agree with the proposal. I would not split NACE 35.11 into to separate classes, because there are only a few producer in Hungary. But I would split CPA 35.11.10 into several separate subcategories, and create a new CPA subcategory for electricity produced from different sources.

Italy Italy has no stance but the risk of creating too detailed classes should be carefully evaluated.

Lithuania We agree the split could be discussed.

Malta Agree

Netherlands Yes, this is necessary, because the production structure of electricity production from renewable sources differs from that of coal and gas etc.

Poland If it is necessary to separate classes for the production of electricity depending on the type of technology for its production in the survey, we propose that they should be added to Division 35. However, we doubt whether this will not be troublesome.


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Sweden Probably there is a public interest in this distinction, but is it necessary for statistical purposes? Perhaps only a distinction between non-renewable and renewable sources?

Switzerland Shouldn't the distinction be made at the national level because of the current structure.


HU: CPA breakdown is ok.RECOMMENDATION:A big majority of countries are in favour of introducing the breakdown between the productions of electricity from renewable sources or not and there is a policy need for this information. 35.11 would be split into 2 classes:

- productions of electricity from renewable sources- productions of electricity from non-renewable sources

Proposal 91PROPOSAL: 34. Code: 35.14 - Trade of electricity Proposal: Where should be classified

charging stations for electricity for cars etc.? Within the charging stations for fuel? They should be mentioned in explanatory notes. The new code is needed. Submitted by: Austria Please provide your comment on this proposal:

Austria Austria thinks, there should be a solution for this problem, this activity is increasing. Austria proposes to include this activity in retail sale of fuel in division 47.

Eurostat E2 Electric charging stations for cars are not comparable to fuel stations, in the sense that the electric stations like a 'plug' operated by the owners of the vehicles. There is no employment involved in operating the electric stations. Car owners must register beforehand in the electricity network.

There is an economic activity to install the electric stations, and to maintain them, and to charge for use, but arguably there is no activity in operating the stations.

The activity to install and maintain the electric stations is alike to distribution of electricity 35.13. The system for car owners to register in the network and pay for use is alike to trade of electricity 35.14.

Croatia Charging stations should be mentioned in explanatory note of class 35.14.

Denmark Agree - that we should solve the question of charging stations for all kind of equipment, including cars, bicycles and phones.

Finland Finland has no position in the matter. The activity will undoubtedly increase a lot within the period of the next NACE. However, most charging stations for electric cars will probably be installed to existing gas stations, to super markets and workplaces. For the time being, it is difficult to assess whether

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charging stations for electricity will form a separate business activity in the future.

France ___________________________________________________________________________________

France position :

We agree with the proposal. In France, we classify this activity in 35.14 Trade of electricity.

NACE notes should be amended, and we should create a new CPA code.

This activity is not only for electricity cars, in France we have a lot of new activities linked to charging.

- For example, we have « juicers ». This word ("juice" is synonymous with electricity) refers to those who collect electric scooters in self-service to recharge them at home, before redeploying them in the early morning. We classify this activity in 35.14.

- We have « pay terminals for mobile phone charging » in some shops or bars, we also classify this activity un 35.14

_____________________________________________________________________________________

France already sent

Germany Agree. As long as trade of electricity is included in division 35 this should also apply for charging stations. For supply activities using a permanent infrastructure (network) it may be a reasonable intension to cover the whole value chain linked to that network within one division.

Greece we believe that it is better to create a new class for the charging stations for electricity for cars.

Hungary Hungary: We don’t support the new code. Explanatory notes should be amended.

Italy The proposal is interesting. There may be two different possibilities:

- enriching the explanatory notes of NACE class 35.14

- modifying the title of NACE class 47.30 and enriching the explanatory notes accordingly (this option is supported by ANFIA - the Italian Association of the Automotive Industry (https://www.anfia.it/)).

Lithuania We agree the code is needed, or strong decision where to classify in present classification and to expand explanatory notes.

Malta Agree

Netherlands A clarification in explanatory notes of the corresponding NACE class is sufficient.

Poland We support Austria’s proposal. We propose to consider two proposals:

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1) in the NACE class 47.30. Retail sale of automotive fuel in specialised stores should be added in the explanatory notes that "this class excludes retail sales of electricity, for motor vehicles". However, in NACE 35.14, add the indent "this class includes the sale of electricity for charging batteries for motor vehicles regardless of the place of its sale";

2) extension of the scope and change of the group name 47.3 to: „Retail sale of automotive fuels and electricity in specialized units”. The change of the previous class 47.30 to: 47.31 „Retail sale of fuel for motor vehicles at petrol stations” and adding class 47.32 „Sale of electricity at electric vehicle charging stations”.

Section G seems to be a better place for this kind of activity than section D, because (at least for now) it has more to do with providing a particular good to the final consumer.

Slovenia We agree.

NACE Rev. 2 does not recognize the business activity of “service of charging stations for electric vehicles” as a separate business service. We therefore propose to add a new classification code for the business activity of charging to electrical vehicles”.

In addition, we would like to remind you that the activity of charging services for electric vehicles can by no means be classified under activity 35.14 - Trade of electricity.

Electricity trading is a regulated activity within the European legislative framework. In the context of trade in electricity, traders conclude mutual contracts, traders or legal persons who, after a closed contract, purchase electricity for resale within or outside the system in which the trader has seat. It is therefore an activity of buying and selling electricity throughout the system. This activity is incomparable with the activity of charging electric vehicles.

Sweden Agree.

Switzerland Currently, they are classified in the 45.20

We could also consider integrating it into 4730, but it must have a commercial aspect.

It may be necessary to adapt the titles of the classes.

United Kingdom Agree that change is needed

It appears that EV charging stations vary greatly in type, for example;

Some are free to use, whilst other require payment by the hour, kilowatt-hour or charge a per session fee.

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In some instance a monthly or annual subscription fee is required.

HU: 35.14 add the indent "this class includes the sale of electricity for charging batteries for motor vehicles, mobile phones etc;in class 47.30. Retail sale of automotive fuel in specialised stores the following exclusion should be added - this class excludes retail sales of electricity, for motor vehicles. However trade is restricted to commodities.

RECOMMENDATION:2 options are proposed to classify charging stations for electricity for cars:

- 35.14 add the indent "this class includes the sale of electricity for charging batteries for motor vehicles, mobile phones etc;in class 47.30. Retail sale of automotive fuel in specialised stores the following exclusion should be added - this class excludes retail sales of electricity, for motor vehicles. However trade is restricted to commodities.

Countries in favour: France, Germany, Croatia, Lithuania, Greece, Hungary, Malta

- Extension of the scope and change of the group name 47.3 to: „Retail sale of automotive fuels and electricity in specialized units”. Split previous class 47.30 to: 47.31 „Retail sale of fuel for motor vehicles at petrol stations” and adding class 47.32 „Sale of electricity at electric vehicle charging stations”. This option would nevertheless not solve the problem of other type of batteries charging activity (mobile phones, electric scooters, etc) .

Countries in favour: Austria, Italy, Finland, Poland, Slovenia, Switzerland, SwedenThe countries not mentioned are invited to give their opinion in order that we can take a decision

PL: Section G seems to be a better place for the retail sale of electricity to motor vehicles, while charging mobile phones, etc. We propose to classify in class 35.14 with the indent "retail sale outside the electricity store network for charging mobile phone batteries etc.

AT: charching stations for handys, Laptops.. are clasified in division 35 by a case law decision. We do´t have any enterprise now that is a charging station for electricity for cars as main activity, mostly this is now secondary activity. We do´t know how this activity will develop. We propose to classify the charging stations in division 47 because it is the same activity you have: charging your diesel car and charging your electric car. FR: We would prefer to add the indent "this class includes the sale of electricity for charging batteries for motor vehicles, mobile phones etc;" in 35.14

Electricity is a particular good/merchandise, its trade is classified in 35. We would not split sale of electricity for cars, mobile phones or electric scooters.

Note : a classification in NAF 47.3 (Retail sale of automotive fuel in specialised stores) may not be relevant because the charging stations (with almost no employees) are available:

- on public car parks;

- on private office or shopping centre car parks;

- on the roads (mainly in large cities such as Paris).

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In this case, the notion of retail trade in specialised stores and the classification in 47.3 can be surprising.

Proposal 92PROPOSAL:

35. Code: 35.22 - Distribution of gaseous fuels through mains Proposal: There is also confusion with 35.22 - Distribution of gaseous fuels through mains and 35.23 -Trade of gas through mains. The description provided by the companies is not as precise to determine whether it is trade or distribution (transport). And if the distribution does not correspond to the trade, should it not correspond to the transport? The definitions of its different activities are not clear enough. We think that no distinction should be made between distribution and transport. We propose to delete 35.22 and keep 49.50 - Transport via pipeline. Submitted by: Switzerland Please provide your comment on this proposal:

Austria Austria: This is the same problem as for group 35.1; we should discuss, what should be measured in the groups 35.1 and 35.2, what should be the content of groups 35.1 and 35.2? What is the activity of the enterprises, classified in the groups 35.1 and 35.2 and what can they report in CPA or PRODCOM?

Croatia We are not in favour of deleting class 35.22 but propose to improve explanatory notes.

Denmark revise notes

Finland Finland agrees that it is not always clear to determine whether gas is distributed or traded.

We interpret that distributing gas to consumers as end-users qualifies as distribution, and importing gas to the country and transporting it to the local gas network is trade.

We experience classifying activities concerning liquefied natural gas (LNG) such as import, storage, wholesale, distribution and trade particularly challenging.

France France notes :

Distribution and trade of gaseouls fuels are two distincts activities. The representant of Data and Statistical Studies Department (SDES - Ministry for the Ecological and Inclusive Transition) pointed out DIRECTIVE 2009/73/EC OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 13 July 2009.

In this directive, the European Council invited the Commission to draw up legislative proposals to ensure 'effective separation of supply and production activities from network management'. Ownership unbundling, which implies that the network owner is designated as the network operator and is independent of supply and production structures, is clearly an effective and stable way to resolve the inherent conflict of interest and ensure security of supply.

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In NACE currently :

---------------------------Transport of gas

- via pipeline (49.50), gaseous

It is the main transmission system : it represents all the pipelines (high pressure and large diameter) that connect neighbouring countries, LNG terminals and gas storage facilities with the regional grid. Its objective is therefore to recover natural gas where it is present and bring it to the various local regions.

- via methane tanker (50.20) , liquid gas

---------------------------Distribution through mains (35.22)

It is the distribution network that transports natural gas to where is your boiler and therefore allows to heat yourself. It includes many smaller diameter pipelines through which natural gas at medium or low pressure flows.

_________________________________________________________________________________

France position :

We disagree with deleting the class 35.22. These are two different activities (not the same equipment, not the same clients).

France suggestion :

(SDES - Ministry for the Ecological and Inclusive Transition) We propose to integrate the activity of transport via pipeline to division 35. Gaseous fuels are not like other goods that are transported in division 49. The activity of gas transport by pipelines does not consist in physically moving gas from point A to point B, but in allowing an injection at point A and an extraction at point B of the same quantity of gas; it is therefore different from a physical transport activity (unlike transport by LNG tanker, which justifies its classification in 50.20).

__________________________________________________________________________________

France already sent

Germany Not agree. 49.50 is only long-distance transport and distribution does not necessarily mean trade. Trade can also use distribution networks owned or operated by a third party. If gas is traded via own mains, distribution should be only an ancillary activity.

Greece we agree


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Italy The risk is splitting the gas industry (NACE group 35.2). European regulations which justify the different groups in NACE division 35 should be investigated.

Lithuania We propose to leave as it is now.

Malta no comment

Netherlands

In the Netherlands the distinction between trade and distribution can be made and is important to make, since these are different economic activities. In the Netherlands the distribution of natural gas and electricity is done by the same companies. A split between 35.22 (distribution of electricity) and 49.50 (distribution of natural gas) would be difficult in practice.

Poland We do not support Switzerland's proposal to delete 35.22 class.

Distribution in a system of mains (class 35.22) is not identical to transport via pipelines (class 49.50). These are different types of activities that can be carried out by different units.


Sweden Agree. Mentioning of small-scale/local distribution of gaseous fuels in 35.22 and mentioning of large-scale distribution of gaseous fuels in 49.50 (pipelines etc.)

Switzerland

Our proposal

United Kingdom

This has not been raised as a concern by UK users, however further clarity would be welcomed

RECOMMENDATION:The 3 concepts: Transport, distribution and trade of gas need clarification.Transport (49.50) - Covers only long-distance transport (high pressure and large diameter) from where natural gas exists and bring it to the local network. Distribution (35.22) brings natural gas to households. Distribution uses a network of smaller diameter pipelines through which natural gas flows at medium or low pressure.Trade (35.21) is the sale of natural gas to users. Distribution does not necessarily mean trade. Trade can also use distribution networks owned or operated by a third party. If gas is traded via own mains, distribution should be only an ancillary activity.

Proposal 93PROPOSAL: 36. Code: E - WATER SUPPLY; SEWERAGE, WASTE MANAGEMENT

AND REMEDIATION ACTIVITIES Proposal: Intermediation of waste products to be added. Submitted by: Italy Please provide your comment on this proposal:

Austria Austria: The problem of classification of intermediation activities must be

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solved for whole NACE classification.

Eurostat E2 It is not clear to us what these 'waste products' are: is it waste or is it a product made of waste and has it still waste characteristics or not?

Currently “Intermediation of waste” should be included in NACE 46.18 “Agents specialised in the sale of other particular goods”. If this becomes a big economic area, NACE 46 would be the right place to add such an activity. (However, the product in this NACE class does not become property of the agent, who intermediates. Thus, such a NACE class might not get a big weight.)

Croatia We agree with the proposal, the activity of brokerage in waste management should be mentioned in explanatory notes of section E.

Denmark Intermediation of waste products sounds more like wholesale in 46.1


France _____________________________________________________________________________________

France position : we don’t understand the proposal. Could you precise this activity ?

If it is an intermediary in waste (waste broker), we propose to classify this activity in 46.18 and to add notes to NACE and CPA.

______________________________________________________________________________________

We found other activities that could be intermediation or trading of waste products (unknown to us till today) :

Trading: any actor in waste management who undertakes, on its own account, the acquisition and subsequent sale of waste, including traders who do not take physical possession of the waste. The trader is the holder of the waste.

Brokerage: any actor in waste management who organises the recovery or disposal of waste on behalf of third parties, including brokers who do not take physical possession of the waste. The role of the broker is to provide a service that connects a waste generator and a disposer. The third party on whose behalf the disposal or recovery is organised shall remain the holder of the waste.

We think these activities should be described in NACE notes, in section G (and not in section E) : waste is a product like any other ; a broker in waste has not a different activity than any other broker in product other than waste. We could specify these services in CPA to collect data if it’s necessary.

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France already sent

Germany Not agree. Correspondingly to "Wholesale of waste and scrap" in class 46.77 intermediation of waste or even of waste products should also be considered in group 46.1 and mentioned there explicitly.

Greece we agree to add this activity to the already existing classes.

Hungary Hungary: This activity will be classified according to the classification rules of intermediary activities, which Task Force will prepare. We don’t agree with the proposal.

Italy During the last years, Italy has received a lot of requests to consider the activity of waste intermediation: intermediation, even without detention, in the management of the waste cycle (collection, treatment, disposal, treatment and recovery).

Lithuania We strongly agree with the proposal.

Malta Agree

Netherlands No opinion.

Poland The proposal is not very precise. We can not relate to it.

Slovenia We have already activities 46.18 Agents specialised in the sale of other particular products;

CPA 46.18.19 Wholesale trade services on a fee or contract basis of other particular products n.e.c.

This subcategory includes sales on a fee or contract basis of:

- paper and paperboard

- wood in the rough

- waste and scrap and materials for recycling

- particular ranges of products n.e.c.

Sweden Why? Need more explaination.

Switzerland 4677?


RECOMMENDATION:Assuming that the activity described is about waste broker this is an entity that companies use as an intermediary between themselves and their trash haulers. Brokers usually take over their clients trash procedures and become the customer of the waste hauler, and

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then in turn bill their clients for trash service.This activity could be explicitly mentioned in 46.18 and a CPA subclass exist already 46.18.19.This conclusion can nevertheless be revised when the Task force will conclude on the treatment of intermediation in services.

Proposal 94PROPOSAL: 37. Code: E - WATER SUPPLY; SEWERAGE, WASTE MANAGEMENT

AND REMEDIATION ACTIVITIES Proposal: It is difficult to clearly define the principal class; most of the units undertake more activities of division 38 following the entire process: waste collection, treatment and recovery. Submitted by: Italy Please provide your comment on this proposal:

Austria Austria: Often enterprises do more than one activity, therefore value added principle must be used. We are against a new class.

Eurostat E2 Unclear proposal.

Croatia We agree that most of the units undertake more activities of division 38, but we follow the rule for determining the main activity.

Denmark Disagree. For example, according to Danish law and EU Regulation, activities connected to Water Supply and Sewage has to be separated from waste handling. A water company's activities related to water supply and sewerage have to be accounted for separately.


France

_______________________________________________________________________________

France position : We agree that it is difficult to define the principal class : the units have usually integrated activities, and if we add the byproducts generated, it is really difficult. The collect of the data by branch is not simple for integrated activities.

_______________________________________________________________________________

During surveys, information is collected by asking companies to breakdown their turnover. But the activity of waste collect or waste treatment generally don’t generate or generate few turnover, the activity that generate turnover is, for the firm, the trade of the products collected, of sorted waste. That is one of the limit of turnover. A lot of firms can be incorrectly classified, only because they declare the turnover for trade. The turnover is not from collect or even treatment, it’s from valorisation.

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How should we treat these integrated and intricated activities ?

So about the byproducts generated : how do we take into account the sell of these byproducts when determining the main activity ?

When the same units (and it’s the common case) carry out all the activities of division 38. It is really difficult between 38.2 Waste treatment and disposal and 38.3 Materials recovery, or even 46.77 Wholesale trade of waste and scraps.

We have a particular problem with units called « casse-automobile » in France (cf. new proposals will be sent in september on this case).

France already sent

Germany We propose no change at that point since collection, treatment and disposal and recovery are the core activities in the value chain of waste management.

Greece we agree. there is a problem with the units that do more than one of the activities of division 38.

Hungary Hungary: These enterprises are now classified in a branch of waste. Don't modify the data if we classify them into a common category?

Italy The proposal is supported by the national association Cisambiente (https://www.cisambiente.it/) and takes into consideration: the state of the art of the technology; the presence of increasingly integrated processes; the organisation of companies; the evolution of the sector in NACE division 38. Such issues in some ways outweigh the tripartition of enterprises in NACE groups 38.1, 38.2 and 38.3 which mainly concerns only smaller enterprises, compared to the largest ones which have developed relevant integrated processes. Waste is an increasingly technology-oriented sector. As a consequence, the breakdown into the above classes is almost incomplete and it is not able to correctly present the value added of the sector itself.

The Italian proposal is the creation of new NACE group 38.4 in order to take into consideration all enterprises which undertake all 3 activities of the sector (NACE groups 38.1, 38.2 and 38.3) but can not properly express their economic value in one group or the other because the classification is not able to catch the activities which are run in an integrated way (e. g. collection together with recovery, recovery together with disposal, and so on).

Lithuania We agree that this is frequent case, but probably we need to use value added principle

Malta Agree

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Netherlands It is not clear what the proposal is.

Poland In accordance with NACE methodological principles, the predominant activity of a statistical unit is the activity with the largest share of the indicator (ex added value, gross production, sales value, employment or remuneration) characterizing the entity's activities.

In statistical surveys, the recommended indicator for determining the prevailing activity is added value

Slovenia We agree. For example, a company that engages in waste treatment simultaneously also collects the waste. In this case it is extremely difficult to decide either for activity 38.1 or for activity 38.2. There are few businesses that merely collect waste or engage merely in waste treatment.

Sweden Agree.

Switzerland It is necessary to define a rule for this kind of case


PL: In Poland, various companies deal with the collection, treatment and recovery of waste.

RECOMMENDATION:In several countries, the waste collection, treatment and recovery are done by the same enterprises. The task force proposes the merge of 38.1 and 38.2. However disposal should be considered a different activity.

Proposal 95PROPOSAL: 38. Code: 37 - Sewerage Proposal: We suggest to move the manufacture

of pellets, briquettes of sewage sludge from 37 (37.00.20) into C - Manufacturing. Our proposal is to create a new separate NACE division/group within C - Manufacturing for the production of alternative fuels of wastes. Reasoning: The alternative fuels of wastes are the same products as those classified into NACE 19, but they are manufactured from wastes. Submitted by: Hungary Please provide your comment on this proposal:

Austria Austria: The same problem is the production of electricity from waste. Sewage sludge is a product of division 37. So the production of pellets from sewage sludge is in 37. If we integrate the production of pellets from sewage sludge in section C, we must integrate the production of electricity from waste in division 35. This could be better implemented on product level classifications (CPA/PRODCOM).

Eurostat E2 This is a specific case of creation of a new physical product out of waste. This type of situations are getting more and more important in the context of recycling, circular economy and production of secondary raw materials. See other cases below.

In principle, we are in favour of making a clear differentiation between

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waste collection/treatment on the one hand and waste recovery on the other. While the former is a service, the latter is the production of a physical product, namely 'secondary raw material' which is fed again into the economy. The production of secondary raw materials has been added recently to the PRODCOM list too.

However this approach must be done with clear rules to determine the borderline between waste collection and waste recovery, and must not be done only for pellets. In some cases, material might lose its waste characteristics already after sorting and become a valuable raw material, which is no longer waste.

Croatia In our opinion, the emphasis is on the treatment of wastewater and we believe that manufacture of pellets, briquettes of sewage sludge should remain in class 37.00.

Denmark Disagree. It is not relevant for Denmark, since we have a long tradition of disposal of waste by utilizing it for production of energy for the households. We've subdivided 38.21 into 38.21.10 treatment and disposal of non-hazardous waste and 38.21.20 disposal with energy production. The municipalities collect our household and commercial waste and send it to the enterprises in 38.21.20, if it's not hazardous. The municipalities also run collection spots where all can go with our discarded goods, including garden waste. The garden waste is composted and when it's ready for use we can go there and pick it up.

Finland We treated proposals 38 and 39 together.

Finland agrees that a new group for production of alternative fuels should be created under section C. Under this group we could create one class for the production of alternative fuels of wastes and another class for biofuels. Alternative fuels of wastes are not always completely biofuel and therefore there should be separate classes for them.

France ____________________________________________________________________

France notes :

The activity of treatment of sewage sludge is not mentioned in NACE or CPA notes. In France, this activity is classified in 37.00 Sewerage (we add it in our national notes).

____________________________________________________________________________

Currently the treatment and recovery of sewage sludge are :

- sewage sludge spreading in agriculture

- recovery in the form of compost sludge methanization that can produce gas

- incineration of sewage sludge that can produce energy and sewage sludge ashes (these ashes can be used in manufacture of products for construction, division 23)

- method of shaping or of compaction of sewage sludge that produce

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pellets. During shaping, the raw material is converted into a on-compacted, relatively homogeneous shape at a very low energy consumption. Post-drying of the shaped pellets is required. During compaction, the material is significantly compacted by the factor 1:2 to 1:4. The energy consumption is higher. Post-drying is not required, here. The material is fed into the press vertically from above using gravity and without any deflectors or other mechanical aids, that means without forced feeding.

_____________________________________________________________________________

France position :

If to activity of « waste treatment of sewage » corresponds the service of waste treatment and the generation of byproduct (sewage sludge), we think the activity should be maintained in division 37.

____________________________________________________________________________

Hungary point out « The alternative fuels of wastes are the same products as those classified into NACE 19, but they are manufactured from wastes. ». The main issue remains the intrant and the process : manufacturing wood pellets (16) is not the same process as manufacturing sewage sludge pellets (not the same intrants, not the same process).

France already sent

Germany Disposal and treatment prior to disposal of solid or non-solid non-hazardous waste by incineration with the resulting production of substitute fuels is already mentioned and classified in 38.21. With these explanatory notes we have a quite clear cut borderline between the treatment of waste and the manufacturing of new products. It may be dangerous to regard waste or treated waste not as output of section E but of section C.

Greece we disagree. Have a specific class for the manufacture of pellets briquettes of sewage sludge in division C probably it will be a very small class.In additional the sewage sludge is not only used as a fuel but also as a fertilizer in agricultural crops.


Italy The first part of the proposal has been accepted in the first part of the consultation (proposal 36 of EU Survey part 1). The definition of “alternative fuel” needs to be clarified: should it be interpreted as part of the chemical industry (NACE division 20) or of the NACE division 19?


Malta no comment

Netherlands Please explore first if these activities fit into an existing NACE class within manufacturing.

Poland We do not support. Hungary’s proposal.

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There is no need to create a new grouping under Section C for the production of alternative fuels from waste.

In CPA Rev. 2.1, division 38 - new sub-categories have been created, i.e:

38.21.50 Pellets of municipal waste

38.32.13 Briquettes, n.e.c. (produced from several different industrial wastes etc.)

In the explanatory notes it should be added that 38.21 class includes the production of alternative fuels of municipal waste, coming from households, hotels, restaurants, hospitals, shops, offices, etc., sweeps from roads and sidewalks, as well as construction and demolition waste, and class 38.22 class includes pellets and briquettes produced from several different industrial wastes, including mixed wastes, ex. metals and plastics.

Slovenia We do not agree with the proposal. Confidentiality issues in small countries.

Sweden Not following – no mention of products in CPA or NACE

Switzerland The manufacture of waste products is not in the 38. We will classify according to activity and not material. For example, pet clothes are classified in 14-Manufacture of wearing apparel

United Kingdom Agree, if the briquetting of sewage sludge and other bio mass result in a final product

PL: We reiterate our proposal that we are against the move of produced pellets / briquettes of sewage sludge to Section C. Pellets / briquettes sewage sludge are in Chapter 38, which deals with the collection, processing and recovery of waste. It seems to be reasonable that the units producing these products deal with the recovery -> pellets / briquettes are the effect of waste recovery.FR: In France, sewer treatment facilities provide the treatment service. This treatment generates sludge powder or granules as a co-product.Some sewer treatment facilities have a fully integrated treatment process and instead of co-generating powder or granules, they produce pellets directly.For these wastewater treatment facilities, we would like to have a reference to the product "sludge pellets" in CPA in 37.00.However, the activity of companies that buy sludge powder or granules from sewage treatment facilities to manufacture pellets from sludge is covered by Section C. The recovery of these sludge powders into pellets is indeed a processing activity falling under Section C.AT: If we consider pellets and briquettes of sewage sludge are maufactured in section C , we must clarify this concept change in explanatory notes very well.

RECOMMENDATION:Manufacturing includes the physical or chemical transformation of materials, substances or components into new products. On this sense the manufacture of pellets, briquettes of sewage sludge should be classified in Section C. However in the past it was decided to

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make an exclusion for the recovery of waste with the justification that “While this may involve physical or chemical transformations, this is not considered to be a part of manufacturing. The primary purpose of these activities is considered to be the treatment or processing of waste and they are therefore classified in Section E (Water supply; sewerage, waste management and remediation activities). However, the manufacture of new final products (as opposed to secondary raw materials) is classified in manufacturing, even if these processes use waste as an input.”

Proposal 96PROPOSAL: 39. Code: 38 - Waste collection, treatment and disposal activities;

materials recovery. Proposal: We suggest to move the manufactured products of wastes from 38 into C - Manufacturing of NACE (e.g. compost, substitute fuels, biogas, briquette, pellet etc.). Our proposal is to create a new separate NACE division/group within C - Manufacturing for the production of alternative fuels of wastes. Reasoning: The alternative fuels of wastes are the same products as those classified into NACE 19, but they are manufactured from wastes Submitted by: Hungary Please provide your comment on this proposal:

Austria Austria: see proposal 38.

Eurostat E2: See previous comment. We are in favour as a question of principle but it must be done with clear rules to determine the borderline between waste collection and waste recovery, and not only for fuel wastes.

NACE class 19 “includes the transformation of crude petroleum and coal into usable products”. Waste is not listed here, on the contrary, other raw materials than crude petroleum and coal are excluded.

Croatia In our opinion, the emphasis is on the treatment of waste and we believe that manufacture the manufactured products of wastes should remain in division 38.

Denmark See comments for no 38 Code 37- sewerage

Finland We treated proposals 38 and 39 together.

Finland agrees that a new group for production of alternative fuels should be created under section C. Under this group we could create one class for the production of alternative fuels of wastes and another class for biofuels. Alternative fuels of wastes are not always completely biofuel and therefore there should be separate classes for them.

France __________________________________________________________________________________

France position :

The treatment of waste can produce various by-products like electricity, gaz.

If it is a byproduct of the activity of waste treatment :

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1. we don’t think it’s pertinent to separate the 2 activities

2. we don’t think that data collecting would be operational if we separate

3. the risk is that the turnover issued from recovery (manufacture of pellets of wastes) would always be higher than the turnover issued from service of waste treatment : we would then empty the group 38.2 or even division 38.

We have to determine a convention/a rule, we fear that with the development fo recovery(valorisation) activities by units that treat waste, if we separate both activities (treatment and recovery/valorisation) then the division 38 could be empty.

____________________________________________________________________________________

France already sent

Germany The relevant borderline between waste treatment and recovery on one hand and manufacturing on the other is along 38.32. As soon as a new final product is manufactured, that activity is in section C, even if the input was waste. But as long as treating, disposing or recovering waste is the aim of the activity this better fits to the management of waste in section E than to the production of new products in section C.

Greece we disagree. have a specific class for the manufacture of alternatives fuels of wastes in sector C probably it will be a very small class.


Italy The definition of “alternative fuel” needs to be clarified and the relative classification should be evaluated as a whole (different proposals concern similar issues).

Lithuania We agree with the proposal

Malta no comment

Netherlands Please explore first if these activities fit into an existing NACE class within manufacturing.

Poland We do not support. Hungary’s proposal.

There is no need to create a new grouping under Section C for the production of alternative fuels from waste.

In CPA Rev. 2.1, division 38 - new sub-categories have been created, i.e:

38.21.50 Pellets of municipal waste

38.32.13 Briquettes, n.e.c. (produced from several different industrial wastes etc.)

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In the explanatory notes it should be added that:

- 38.21 class in NACE includes the production of alternative fuels of municipal waste, coming from households, hotels, restaurants, hospitals, shops, offices, etc., sweeps from roads and sidewalks, as well as construction and demolition waste,

- 38.22 class in NACE includes pellets and briquettes produced from several different industrial wastes, including mixed wastes, ex. metals and plastics.

Slovenia We partly agree with the proposal that the use of secondary raw materials, which are a product of waste recycling and have lost the status of waste, is to be shifted into the appropriate processing activity (Group C). Let us call it »appropriate« because not only fuel, but also plastic, metal, paper, etc., are the product of waste recycling. Within the framework of the principles of the circular economy, data on how much secondary raw materials are used - raw materials derived from waste - are extremely in demand. Such a breakdown would also make sense in other manufacturing industries (metal, paper industry, construction, etc.).

Sweden Not following – no mention of products in CPA or NACE

Switzerland The manufacture of waste products is not in the 38. We will classify according to activity and not material. For example, pet clothes are classified in 14-Manufacture of wearing apparel


PL: We reiterate our proposal that we are against the transfer of produced pellets / briquettes of sewage sludge to Section C

RECOMMENDATION:Same recommendation as proposal 95

Proposal 97PROPOSAL: 40. Code: 38 - Waste collection, treatment and disposal activities;

materials recovery Proposal: Make explicit in this division the activities of collection, treatment of animal by-products - Regulation (EC) nº 1069/2009. Change the description of the following NACE codes: 38 – Waste and animal by-products collection, treatment and disposal activities; materials recovery 38.1 - Waste and animal by-products collection 38.11 - Collection of non-hazardous waste and animal by-products 38.11 - Collection of non-hazardous waste and animal by-products 38.12 - Collection of hazardous waste and animal by-products 38.2 – Waste and animal by-products treatment and disposal 38.21- Treatment and disposal of non-hazardous waste and animal by-products 38.22 - Treatment and disposal of hazardous waste and animal by-products Submitted by: Portugal Please provide your comment on this proposal:

Austria Austria is against this proposal, because the animal by products are already included in waste and not relevant for all countries in Europe.

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Eurostat E2: See previous comment.

Croatia In our opinion, there is no need to add to the title “animal by-products”, explanatory notes can be amendment where necessary.

Denmark no comment at this moment


France

____________________________________________________________________________________

France position :

We don’t think it’s a necessity to add the precision in the heading of the class.

But we could improve NACE notes and precise it’s the collection, disposal and treatment of animal byproducts (products intended for destruction which can no longer be used as intermediate products by the food industry, for example).

We would prefer not to mention the Regulation (as it could be amended, amended or repealed).

______________________________________________________________________________________

France already sent

Germany The wording "waste" does already include all kind of waste. We don't see the necessity to emphasize animal by-products in such a way. This may also cause some borderline problems since production of gas for the purpose of gas supply from by-products of agriculture is explicitly mentioned in class 35.21.

Greece we propose to create a new class in the division 38 for the activities of collection, treatment and disposal of animal by-products.

Hungary Hungary: We don’t agree with the proposal, because we don’t handle waste and animal by-products in the same category in Hungary

Italy NACE classification, being a statistical classification of economic activities shouldn’t be dependent from regulations even if regulations usually help to understand special activities providing interesting and useful details. Italy is not in favour of the proposal because it doesn’t add information to the title; non-hazardous waste already contains animal by-products ones. By adding the wording “animal by-products” the risk is excluding other kind of waste such as those deriving from vegetables.

Lithuania We agree the descriptions could be changed.

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Malta no comment


Poland We do not support Portugal's proposal.

Supplementing the explanatory notes of Division 38 will be sufficient, without changing names of each class.

We propose in the explanatory notes to add more details:

- Class 38.11 also includes: - collection of waste and by-products of animal origin not intended for human consumption, not posing a risk to human and animal health

- Class 38.12 also includes: - collection of waste and by-products of animal origin not intended for human consumption, posing a risk to human and animal health

- Class 38.21 also includes: - the processing and disposal of waste and by-products of animal origin not intended for human consumption, not posing a risk to human and animal health

- Class 38.22 also includes: - the processing and disposal of waste and by-products of animal origin not intended for human consumption, posing a risk to human and animal health.

Slovenia In our opinion, there is no need to specifically include animal by-products in E38. The animal by-product does not necessarily have to be waste and is partly also excluded from waste legislation. If an animal by-product is shifted to processing of animal feed, then it is not treated as waste, but as a by-product. If, for various reasons, the animal by-product does not go to processing into animal feed, but goes into the waste management system, then we are already talking about waste. These are not just animal by-products that should then be separately included in group 38. Other "by-products" or residues that are no longer waste should therefore be specifically mentioned in the description of the name (metals, earth, wood, etc.), but this is not relevant, as this is in fact not waste. See also the comment under Code 39.

Sweden Good suggestion! However is “biological waste” a more fitting description than animal by-products?

Switzerland It'is too specific


RECOMMENDATION:Not considered important to mention animal by-products in the titles of Division 38, groups 38.1 and 38.2 and respective classes as, in this context, animal by-products are anyway waste.

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However, it could be added in the explanatory notes the following text:

- Class 38.11 also includes: - collection of non-hazardous waste by-products of animal origin - Class 38.12 also includes: - collection of hazardous waste by-products of animal origin - Class 38.21 also includes: - the processing and disposal of non-hazardous waste by-products of animal origin - Class 38.22 also includes: - the processing and disposal of hazardous waste by-products of animal origin

Proposal 98PROPOSAL: 41. Code: 38 - Waste collection, treatment and disposal activities; materials

recovery Proposal: Create a new class/group 38.XX - Waste management activity. We have enterprises for each branch of wastes, who has the responsibility to control (management) the enterprises which has the activity of waste collection, treatment, disposal, recovery, etc. Submitted by: Portugal Please provide your comment on this proposal:

Austria Austria has enriched its national explanatory notes. No new class, but enrich the explanatory notes of NACE Rev.2.

Eurostat E2: See previous comment.

Croatia What is meant by “control the enterprise”? Is it some kind of inspection? Is the enterprise responsible for the waste collection, treatment? We need more information on this.



France

_________________________________________________________________

France notes :

We don’t understand clearly what « waste management activity » is.

_________________________________________________________________

-------------------> If the activity of the unit is to control the activity of other units, it’s potentially an activity of head office, isn’it ? Why should we make a difference for the activity of management of units which have the activity of waste collection ?

-------------------> If the activity of the unit is "waste management" in the sense in which it outsources a part or the whole services activities, then it is outsourcing of

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services and the unit should be classified as if it carried out the complete services activity.

-------------------> We found on internet this definition : Waste management (or waste disposal) are the activities and actions required to manage waste from its inception to its final disposal. This includes the collection, transport, treatment and disposal of waste, together with monitoring and regulation of the waste management process.

In this case, it covers all the activities described in division 38, completely integrated (cf. notes on proposal 37)

-------------------> It could maybe also be, if carried out by authorities, the activity of administration of waste collection and disposal operations (class 84.12).

Currently in NACE, we can find the activity of "consulting in waste management" in 74.90

74.90.13 Environmental consulting services

waste management consulting, i.e. provision of objective information, advice, or guidance concerning the best practices for the minimisation, transport, handling, disposal and/or recycling of waste

For "waste broking", we should add a note in NACE in 46.18

What other activity can it be ? Could you give a description of this activity ?

France already sent

Germany Companies which are not collecting, transporting, sorting and recycling itself but have subcontracted these activities nevertheless are rendering these services by contract and are therefore also responsible for fulfilment and have to be classified as if they would render the service itself. Companies who only control the processes but have not subcontracted them should be classified in 71.12 or 74.90.

Greece we disagree because it will be a very small class. In additional we believe that the waste management activity could be classified in the division 70.

Hungary Hungary: These enterprises are now classified in a branch of waste. Don't modify the data if we classify them into a common category?

Italy The proposal is not very clear; the description provided “control/management”

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suggests the activity of a head-office; is it maybe an intermediation activity and thus similar to proposals 36 and 37?

Lithuania We strongly agree with the proposal. In Lithuania waste management activity now regulated and we don't have place for them in NACE, these companies don't agree to be classified in any class of 38 division, as these classes do not correspond to this activity.

Malta no comment


Poland We do not support Portugal's proposals.

There is no need to create a new class related to waste management activity.

This activity falls under NACE 74.90 (CPA 74.90.13).

We propose adding an indent in the NACE 74.90 regarding activities related to waste management.

Slovenia We do not agree with the proposal. Confidentiality issues in small countries.

Sweden Is this due to national legislation? Is it a part of public management? Then perhaps 84.11? Is it management as in head office (70.10)? or Perhaps 74.90?

Switzerland Does he really have a lot of management activity without the treatment? Shouldn't it be included in the same code


RECOMMENDATION:Further clarifications are needed on what exactly these companies are doing before taking a decision. Clarifications will be asked to Portugal.

Proposal 99PROPOSAL: 42. Code: 38.21 - Treatment and disposal of non-hazardous waste

Proposal: It is difficult to understand how to burn waste for gas or electricity. Shouldn’t this be attributed to the production of electricity or gas? Submitted by: Lithuania Please provide your comment on this proposal:

Austria Austria: See proposal 38

Eurostat E2: incinerating waste to produce gas or electricity both a waste treatment (to get rid of the waste) and production of electricity/gas. The situation is analogous to the other cases above: there is a sequence of activities, first there is waste collection and treatment, and then another activity down the chain, in this case to produce energy (in the previous cases it was to produce secondary raw materials).

Croatia In our opinion, the emphasis is on the treatment of waste and by-product is electricity. Similar as proposals 38 and 39.

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Denmark Disagree. Denmark has a long tradition of disposal of waste by utilizing it for production of energy for the households. We've subdivided 38.21 into 38.21.10 treatment and disposal of non-hazardous waste and 38.21.20 disposal with energy production. The municipalities collect our household and commercial waste and send it to the enterprises in 38.21.20, if it's not hazardous. The municipalities also run collection spots where all can go with our discarded goods, including garden waste. The garden waste is composted and when it's ready for use we can go there and pick it up.

Finland Finland agrees with the proposal.

Finland currently classifies the activity of burning non-hazardous waste into energy under Division 35 Electricity, gas, steam and air conditioning supply. It has been approved by all statistical domains using NACE, and we would like to keep it unchanged. For the sake of European comparability, TF needs to take a decision in the matter.

France ___________________________________________________________________

France position :

We agree that on one occasion the process and the products described in class 35.21 and 38.21 can be the same.

We mainly encounter this problem in France with the agricultural methanisation activity which is in significant development.

___________________________________________________________________

Methanisation in France is a sector of agro-industrial activity that allows the recovery of organic waste by producing biogas. Resources can be urban waste or residues from agricultural or agro-industrial activities. Biogas can be burned at its place of production, injected into the natural gas distribution network or used as a biogas fuel.

Currently, in France, for business register agents, a unit which produces gas or electricity can be classified in 2 different places in NACE.

Indeed, a company that treats waste by methanisation and thus produces electricity can be classified :

- in 35.21 : the company (A) buys waste, and decide to produce gas or electricity by methanisation. The turnover of the unit is made of 1 branch of activity : production of energy (35.21 ou 35.11)

- in 38.21 : the company (B) provides a services of waste treatment to units which have waste and have to treat them (get rid of them). The turnover of the unit is made of 2 branches of activity : service of waste treatment (38.21) and trade of energy (=byproduct).

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__________________________________________________________________________

French questions :

Based on NACE notes, we have 3 interrogations :

1. NACE notes described « economic activity » as : an economic activity takes place when resources such as capital goods, labour, manufacturing techniques or intermediary products are combined to produce specific goods or services. Thus, an economic activity is characterised by an input of resources, a production process and an output of products (goods or services).

In the case previously described, company (A) and company (B) have the same input (waste), the same process (methanization) and produce the same goods. Why would we classify the activity in two different classes ?

2. In the case of company (B), the representative of Data and Statistical Studies Department (SDES - Ministry for the Ecological and Inclusive Transition) pointed out that with a branch of activities "service of waste treatment" and a branch of activity "trade of energy", based on the breakdown of turnover, the main activity of company (B) will be trade of energy and not service of waste treatment.

3. When data is collected during the survey, we ask the firm to breakdown turnover depending on activities. But usually, they declare that turnover is generated by the production of energy (35), these firms rarely declared turnover for treating waste (38) even if they do treat waste.

France already sent

Germany The production of gas from waste for the purpose of gas supply is indeed already classified in class 35.21. The production of electricity through a waste-incineration process is, besides the exclusion in 35.11, also mentioned in the introduction of ISIC Rev.4 as an example for horizontal integration. The activity of

waste disposal and the activity of electricity production cannot be separated in this case and ISIC Rev.4 just assigned them, by convention, to class 3821.

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Greece we believe that this activity is preferable to remain in this class

Hungary Hungary: We don’t agree with the proposal.

Italy If you burn waste to produce gas and electricity you should not be classified in NACE class 38.21 but in the most appropriate classes. As a consequence, we should include in NACE class 38.21 waste which is burnt not to produce energy.

Lithuania Our question.

Malta no comment

Netherlands It is not clear what the proposal is.

Poland Activities related to the disposal of non-hazardous waste through incineration or other methods may be accompanied by the production of electricity, steam, compost, substitute fuels, biogas, ash or other by-products for further use, etc.

The activities related to the generation of electricity through incineration fall under NACE 38.21 (corresponding entry in the exclusions of class 35.11)

Slovenia We think that this will be a more minimal production, but rather a by-product.

Sweden Consider the explanatory notes for Section C. “The primary purpose of these activities is considered to be the treatment or processing of waste and they are therefore classified in Section E (Water supply; sewerage, waste management and remediation activities).” Is the primary purpose to treat and process waste or to produce gas, electricity or for heating?

Switzerland If the company only produces electricity ok, otherwise no, they do the treatment.


RECOMMENDATION:The incineration of waste to produce gas or electricity they should be classified in 35.21 or 35.11This recommendation is consistent with the recommendation made on proposals 95 and 96.

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