nace review · 2019. 7. 12. · includes impregnation or chemical treatment of wood with...

EUROPEAN COMMISSION EUROSTAT

NACE review

PLANNED WORKING ROADMAP

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A - AGRICULTURE, FORESTRY AND FISHING

01 - Crop and animal production, hunting and related service activities

Germany If units manufacture food products from own-produced agricultural products, according to NACE Rev. 2 these units will be classified in agriculture by convention. This is not in line with the (value added) concepts from ISIC and may lead to inconsistencies.

Type of change: Other change Comment:

01.1 - Growing of non-perennial crops

Finland Is the split between non-perennial and perennial relevant? Type of change: Aggregation Comment:

01.13 - Growing of vegetables and melons, roots and tubers

Estonia Please remove Latin term capsicum sop form the description of this class. Capsicum sop is both sweet pepper and chilli pepper. Please add to the description that growing of sweet pepper has to be classified into this class.

Type of change: Correction of mistakes Comment:

01.28 - Growing of spices, aromatic, drug and pharmaceutical crops

Estonia Please add to the description of this class that sweet pepper is excluded from this class. Type of change: Correction of mistakes Comment:

01.50 - Mixed farming

Finland Is the split between specialised production of crops or animals and non-specialised production of crops and animals relevant?

Type of change: Aggregation Comment:

01.6 - Support activities to agriculture and post-harvest crop activities

Italy NACE group 01.6 needs to be better defined in order to make clearer the classification differences with the following activities: • preparation of agricultural products by the producer • marketing activities of commission merchants and cooperative associations, see division 46

Type of change: Complete explanatory notes Comment:

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01.62 - Support activities for animal production

France The limits between engineering and research: > when does a research activity (72) become an engineering activity (71)? > how to draw the line between research (72) and activities to promote propagation, growth and output of animals (01.62)?

Type of change: Blur boundaries Comment:

02.20 - Logging

Slovenia NACE 02.20 Logging should include wood chips: One of the line should read: »production of wood, wood chips, collection of brushwood and forest waste for energy production« Raw wood categories are timber of forest species, with or without bark, covering: round wood, split or in other form (branches, roots, stumps and burls), and wood chips from wood gathered directly in the forest. NACE 16.10 Saw milling and planning of wood should exclude wood chips, since wood chips are not processed wood.


07.10 - Mining of iron ores

Bulgaria In the modern world has a narrow specialization in the sector B "Mining and quarrying". The mining units do not carry out the operations of agglomeration and concentration of ores.


07.2 - Mining of non-ferrous metal ores



07.21 - Mining of uranium and thorium ores



07.29 - Mining of other non-ferrous metal ores



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08.12 - Operation of gravel and sand pits; mining of clays and kaolin

Bulgaria There are two different activities - like NACE Rev.1.1.: 08.12 Operation of gravel and sand pits 08.13 Mining of clays and kaolin

Type of change: New code Comment:

C - MANUFACTURING

Austria In section C classes for processing and finishing of materials like wood or plastics are missing Type of change: New code Comment:

Lithuania Separate class for Manufacture of photovoltaic products and equipment Type of change: New code Comment: Photovoltaic technology sector is growing and that should be reflected in NACE

10.11 - Processing and preserving of meat

Bulgaria Change title of 10.11 and 10.12 - The preserved meat and meat products are classified under 10.13 10.11 Processing of meat 10.12 Processing of poultry meat


10.12 - Processing and preserving of poultry meat

Bulgaria Change title of 10.11 and 10.12 - The preserved meat and meat products are classified under 10.13 10.11 Processing of meat 10.12 Processing of poultry meat


10.13 - Production of meat and poultry meat products

France Sharing between event catering activities (56.21), production of meat products (part of 10.13) and retail sale of meat and meat products in specialised stores (47.22) (services, industry, trade) must also be clarified.


10.89 - Manufacture of other food products n.e.c.

Poland The proposal of breaking down of class 10.89 on: Manufacture of food supplements suitable for human consumption Manufacture of other food products n.e.c.

Type of change: Split Comment: Due to the dynamic development of the market of food supplements, the present section off will make possible identification and classifying the producers involved in this kind of activity

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11.02 - Manufacture of wine from grape

Bulgaria This class excludes wine from dried grapes (for example currants, sultanas) - 11.03 - see also CPA Ver.2.1. Proposal: 11.02 Manufacture of wine from fresh grapes


11.07 - Manufacture of soft drinks; production of mineral waters and other bottled waters

Hungary “The production of ice, for food and non-food (e.g. cooling) purposes” is explicitly mentioned in the explanatory notes of NACE 35.30 “Steam and air conditioning supply”. In line with that CPA 35.30.21 includes “Ice, including ice for cooling (i.e. non-food) purposes”. But in the correspondence table CN 2201 90 00 has a link to CPA 11.07.11. PRODCOM has the same item in 11.07.11.50. Proposal: We suggest to split the manufacture of ice into 2 classes: ice for food purpose: 11.07, ice for non-food purpose (e.g. cooling): 35.30.

Type of change: Split Comment:

13 - Manufacture of textiles

Austria The activity of textile printing should be classified in division 13 of NACE Rev.2. Type of change: Correction of mistakes Comment:

Denmark Class 13.95 - Why have a class, which excludes apparel in the title, and which is supposed to include items from both divisions, when division 14 specifically includes apparel and therefore is excluded from 13.95. The explanatory notes should be changed


13.30 - Finishing of textiles

Sweden ”silk-screen printing on textiles and wearing apparel” should be a part of 18.12, not 13.30 in NACE, in accordance with CPA 2.1


14 - Manufacture of wearing apparel

Denmark Class 13.95 - Why have a class, which excludes apparel in the title, and which is supposed to include items from both divisions, when division 14 specifically includes apparel and therefore is excluded from 13.95. The explanatory notes should be changed


France We would also be interested in the possibility of distinguishing clothing linked to the practice of a sporting activity within clothing, but this is perhaps a rather overly ambitious course of action.

Type of change: New code

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Comment:

Portugal Create new class 14.15 – Manufacture of sport apparel and accessories

Type of change: New code Comment: This is a proposal from our colleagues of “Sport Statistics”

Slovenia T-shirts and shirts are not underwear, so they do not belong into NACE 14.14. A more appropriate classification would be 14.13 Manufacture of other outwear or they should be classified into a completely new, separate activity. It would be better to divide clothing based on material they are made of (cotton, silk, satin, wool, etc.) instead of the type of fabric (woven, knitted, crocheted, non- woven).

Type of change: Restructuring Comment:

15.12 - Manufacture of luggage, handbags and the like, saddlery and harness

Lithuania Separate manufacture of handbags, suitcases and so on from all other articles and products of leather.

Type of change: Split Comment: A very wide range of products in one class.

16 - Manufacture of wood and of products of wood and cork, except furniture; manufacture of articles of straw and plaiting materials

Portugal Create a new Group 163 – Cork industry Create new Classes: 1631 - Cork preparation industry 1632 – Manufacture of cork stoppers 1633- Manufacture of cork agglomerates products 1639 - Manufacture of other cork products

Type of change: New code Comment: This is a proposal from APCOR (Associação Portuguesa da Cortiça) APCOR is the employers’ association of the cork sector.

16.10 - Sawmilling and planing of wood

France Wood impregnation: for the treatment of framing: what are the limits between 16.10 (This class also includes impregnation or chemical treatment of wood with preservatives or other materials), 81.29 (This class includes disinfecting and exterminating activities) and 43?


Slovenia NACE 02.20 Logging should include wood chips: One of the line should read: »production of wood, wood chips, collection of brushwood and forest waste for energy production« Raw wood categories are timber of forest species, with or without bark, covering: round wood, split or in other form (branches, roots, stumps and burls), and wood chips from wood gathered directly in the forest.

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NACE 16.10 Saw milling and planning of wood should exclude wood chips, since wood chips are not processed wood.


Slovenia Production is changing; there are ever more new products (briquettes, pellets, etc.) and production methods. It would therefore be appropriate to adjust the codes accordingly.


16.2 - Manufacture of products of wood, cork, straw and plaiting materials

Portugal Group 162 create a new class 1625 –Manufacture doors and windows of wood Type of change: New code Comment: (proposal by ANFAJE - ANFAJE mission is to ensure the representation, the study and defence of associates and the dissemination of Efficient Windows)

16.21 - Manufacture of veneer sheets and wood-based panels



16.22 - Manufacture of assembled parquet floors



16.23 - Manufacture of other builders' carpentry and joinery

France Several classes relate to the manufacture/installation of furniture: Class 16.23 includes manufacture of wooden goods, dont doors, manufacture of wood partitions; boundaries with the following classes must be specified : 31.01 (Manufacture of office and shop furniture, 31.09 (Manufacture of other furniture), 43.32 (Joinery installation).


16.29 - Manufacture of other products of wood; manufacture of articles of cork, straw and plaiting materials

Lithuania Biofuel should have separate class Type of change: Split Comment: A very wide range of products. The biofuel production is also included there. The need for the statistics on biofuel production is growing.

Slovenia The production of burial coffins, now classified in NACE 32.99 Other manufacturing n.e.c. should be classified in NACE 16.29 Manufacture of other products of wood; manufacture of articles of cork, straw

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and plaiting. In accordance with international regulations for ecological and other reasons, coffins cannot be made from other materials such as wood. In Slovenia, the production of coffins represents one of the major processors of timber in Slovenia.


17 - Manufacture of paper and paper products

Switzerland Some activities need to be analysed. There is a loss of importance in certain areas and we should be more in tune with the reality. For example: 17- Manufacture of paper and paper products, 18- Printing and reproduction of recorded media, 47.63- Retail sale of music and video recordings in specialized stores.


18 - Printing and reproduction of recorded media

France The publishing activities seem poorly explained for the BR operators: they have trouble differentiating between 58, 18, 60, 62


Hungary It is difficult to find a borderline between 18 and 82.19. The explanatory notes of 82.19 say: “The document copying/printing activities included here cover only short-run type printing activities” Is this the principal? Or only “office support activities” are included in 82.19? Copy General company is classified into 82.19 in the Hungarian BR. We have doubts about it. We would classify Copy General into 18, according to its activity.


Hungary NACE division 18 is outdated. Traditional printing technology has been disappearing and PC driven technology is increasing. So structure and explanatory note so division 18 should be completely revised.


Slovenia In the past 20 years printing has undergone numerous changes. Classical printing is practically extinct. Everything is done digitally. In addition to printing, enterprises perform other activities such as graphic design of the final product, etc., and they have difficulties distinguishing between individual activities. Codes should be adjusted to new production methods.




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18.12 - Other printing

France The most difficult activities to classify and the main source of litigation comes from division 18 of the nomenclature, in particular classes 18.12 and 18.13. Very clearly, the boundary between class 18.12 (industrial service) and services is not always bright.


France Design and advertising: advertising printing companies want to be classified as advertising (18.12 vs. 73.11). These companies estimate that they design the advertisements (perhaps it is necessary to better describe in 73.11 the design part of the advertising campaign)


Sweden ”silk-screen printing on textiles and wearing apparel” should be a part of 18.12, not 13.30 in NACE, in accordance with CPA 2.1


18.13 - Pre-press and pre-media services

France The most difficult activities to classify and the main source of litigation comes from division 18 of the nomenclature, in particular classes 18.12 and 18.13. Very clearly, the boundary between class 18.12 (industrial service) and services is not always bright.


France Graphic designers want to be classified in 18.13: could the notes better describe 18.13 or quote the graphic designer in 74.10?


19.20 - Manufacture of refined petroleum products

Lithuania Change class name or separate granules and briquettes from coal and organic matter „pellets and briquettes of organic fossils“

Type of change: Other change Comment: The name of the class does not reflect that there is included not only petroleum products.

20.11 - Manufacture of industrial gases

France In the chemical sector (CPA 20), we have a concern to classify gases into mixtures. In principle, the classification of the mixture must be done at the most specific position, i. e. that which gives the mixture its character. For example, an anaesthetic gas will be classified in 20.11.12 (Carbon dioxide and other inorganic oxygen compounds of non-metals) because it is the nitrogen compounds that give the anaesthetic character. However, some companies in the sector manufacture a lot of them (between 400 and 1200 depending on the company) and are therefore not able to indicate their specific content.


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20.59 - Manufacture of other chemical products n.e.c.

Lithuania A very wide range of products in this class and there is also a biodiesel is classified. As a part of biofuel: A biofuel is a fuel that is produced through contemporary biological processes, such as agriculture and anaerobic digestion, rather than a fuel produced by geological processes such as those involved in the formation of fossil fuels, such as coal and petroleum, from prehistoric biological matter. Different types of biofuel: Ethanol; Biodiesel; Other bio alcohols; Green diesel; Biofuel gasoline; Vegetable oil; Bio ethers; Biogas; Syngas The interest is big and should be reflected in economic sectors.


Poland The proposal of breaking down of class 20.59 on: Manufacture of biofuels Manufacture of other chemical products n.e.c.

Type of change: Split Comment: The proposal of section off of the class arises from dynamic development of the liquid biofuels and it will make possible identification and classifying the producers involved in this kind of activity, and scrutiny the condition of dynamically developing branch of the chemical industry

22.2 - Manufacture of plastic products

Lithuania Provide more explanatory notes on different kind of plastics or separate these kind of plastics Type of change: Complete explanatory notes Comment: This group also includes products from glass fibber, silicone or polymer clay.

23.12 - Shaping and processing of flat glass

France In the glass sector, vehicle mirrors are classified in NACE 23.12 (Shaping and processing of flat glass) under product code 23.12.13. But over the years technology has evolved a lot. Mirrors are equipped with multiple functions and manufacturers themselves would like these items to be brought closer to the Manufacture of parts and accessories for motor vehicles (Gr.29.3).


24.5 - Casting of metals

Italy A wording revision has to be made in NACE group 24.5 and the inclusions have to be updated. Type of change: Complete explanatory notes Comment:

25 - Manufacture of fabricated metal products, except machinery and equipment

Lithuania Metal products such as fences, gates, railings, stairs, doors, windows, etc. building elements should be grouped into one class

Type of change: New code Comment: It would be preferable to group builder‘s ware of metal in one class, as in other C section divisions or in trade.

Portugal Turn the class 2573(Manufacture of tools) into a group 258 (Manufacture of tools) and create the following new classes:

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2581 – Manufacture of hand tools 2582 – Manufacture of mechanical tools 2583 – Manufacture of sintered parts 2584 – Manufacture of metal moulds

Type of change: Restructuring Comment: This is a proposal from CEFAMOL - Portuguese Association for the Moulding Industry

25.21 - Manufacture of central heating radiators and boilers

Germany There is no clear-cut coding of central heating boilers/furnaces in the current NACE. This seems to be a problem induced with the last revision of ISIC. Whereas class 28.21 got more content, the content of class 25.21 was not reduced equivalently. Proposal of change: Creation of a clear-cut borderline between classes 25.21 and 28.21


26 - Manufacture of computer, electronic and optical products

Germany 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.


Germany 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


Hungary 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.)


27 - Manufacture of electrical equipment

Germany 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.


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

France 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.


Germany 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.


28.21 - Manufacture of ovens, furnaces and furnace burners

Germany There is no clear-cut coding of central heating boilers/furnaces in the current NACE. This seems to be a problem induced with the last revision of ISIC. Whereas class 28.21 got more content, the content of class 25.21 was not reduced equivalently. Proposal of change: Creation of a clear-cut borderline between classes 25.21 and 28.21


Lithuania Refine the name of the class, e.g. „Heating equipment“ or separate class Type of change: Other change Comment: Classification of solar collectors and other domestic non electric heating equipment (wind water, geothermal).

28.4 - Manufacture of metal forming machinery and machine tools

Germany The split of ISIC Rev.4 class 2822 (“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 aspects. Machine tools for turning, drilling, milling, shaping, planing, boring, grinding etc., mentioned in the explanatory notes from class 28.41, are no metal forming machinery. Proposal of change: Restructuring group 28.4


28.92 - Manufacture of machinery for mining, quarrying and construction

Italy Manufacture of snow groomers to be added Type of change: Complete explanatory notes Comment:

28.99 - Manufacture of other special-purpose machinery n.e.c.

Hungary The manufacture of automatic bowling alley equipment (e.g. pin-setters) is explicitly mentioned in the

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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. Proposal: We suggest to move the manufacture of automatic bowling alley equipment (e.g. pin-setters) from 28.99 to 32.40.

Type of change: Restructuring Comment: Reasoning: this equipment can be used for automatic bowling only.

29 - Manufacture of motor vehicles, trailers and semi-trailers

Germany 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.


29.10 - Manufacture of motor vehicles



29.3 - Manufacture of parts and accessories for motor vehicles

France In the glass sector, vehicle mirrors are classified in NACE 23.12 (Shaping and processing of flat glass) under product code 23.12.13. But over the years technology has evolved a lot. Mirrors are equipped with multiple functions and manufacturers themselves would like these items to be brought closer to the Manufacture of parts and accessories for motor vehicles (Gr.29.3).


30.1 - Building of ships and boats

United Combine shipbuilding repair (33.15) with shipbuilding (30.1). Type of change: Aggregation Comment: Repair is not a single industry - separating the repair form the manufacture doesn’t allow for the industry as a whole to be measured.

30.30 - Manufacture of air and spacecraft and related machinery



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Lithuania 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

Type of change: Split Comment: 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??

United 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)

Type of change: New code Comment: 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

30.40 - Manufacture of military fighting vehicles

Estonia Please add to the description of this class that repair and maintenance of such vehicles has to be classified into this class.


31 - Manufacture of furniture

Germany 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. Proposal of change: None. The approach should be reviewed.


Hungary We propose to harmonise the structure at 4 digit level of CPA with that of NACE. Type of change: Other change Comment: 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.

31.01 - Manufacture of office and shop furniture



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31.03 - Manufacture of mattresses

France Class 31.03 (Manufacture of mattresses): add in the wording the mention of the box springs. Type of change: Complete explanatory notes Comment:

31.09 - Manufacture of other furniture



Slovenia 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.


32.40 - Manufacture of games and toys

Hungary 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. Proposal: We suggest to move the manufacture of automatic bowling alley equipment (e.g. pin-setters) from 28.99 to 32.40.

Type of change: Restructuring Comment: Reasoning: this equipment can be used for automatic bowling only.

32.5 - Manufacture of medical and dental instruments and supplies

Malta NACE 32.5, Manufacture of medical and dental instruments and supplies should be distinguished at 2- digit.


32.50 - Manufacture of medical and dental instruments and supplies

France 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?

Type of change: Comment:

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32.99 - Other manufacturing n.e.c.

Lithuania 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 be very specific and innovative with different high-tech technologies therefore comparing to the rest list of products in this class should be excluded.


Slovenia The production of burial coffins, now classified in NACE 32.99 Other manufacturing n.e.c. 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 such as wood. In Slovenia, the production of coffins represents one of the major processors of timber in Slovenia.


33.1 - Repair of fabricated metal products, machinery and equipment

Malta 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


33.15 - Repair and maintenance of ships and boats

United Combine shipbuilding repair (33.15) with shipbuilding (30.1). Type of change: Aggregation Comment: Repair is not a single industry - separating the repair form the manufacture doesn’t allow for the industry as a whole to be measured.

33.16 - Repair and maintenance of aircraft and spacecraft

United 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)

Type of change: New code Comment: 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

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defence

35 - Electricity, gas, steam and air conditioning supply

Germany Expanding supply of renewable energy is demanding a growing importance of short and also long term storage of energy. Proposal of change: Creation of one or more categories for storage of energy, maybe even considering the storage of gas, currently regarded as warehousing.


Germany 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


Lithuania The production of electricity from renewable sources is increasing. It is necessary to separate this kind of activity and should be reflected in NACE


35.1 - Electric power generation, transmission and distribution

France The classification of electrical energy production does not distinguish the type of energy: nuclear, photovoltaic,…


35.22 - Distribution of gaseous fuels through mains

Switzerland Increased clarity in the explanatory notes would be beneficial for understanding and result in a better classification. There are more examples of the same type such as 3522 versus 4950 etc.


35.3 - Steam and air conditioning supply

Lithuania Exclude production of ice for food and human consumption from this group, as should be in C section


35.30 - Steam and air conditioning supply

Hungary “The production of ice, for food and non-food (e.g. cooling) purposes” is explicitly mentioned in the explanatory notes of NACE 35.30 “Steam and air conditioning supply”. In line with that CPA 35.30.21 includes “Ice, including ice for cooling (i.e. non-food) purposes”. But in the correspondence table CN 2201 90 00 has a link to CPA 11.07.11.

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PRODCOM has the same item in 11.07.11.50. Proposal: We suggest to split the manufacture of ice into 2 classes: ice for food purpose: 11.07, ice for non-food purpose (e.g. cooling): 35.30.


E - WATER SUPPLY; SEWERAGE, WASTE MANAGEMENT AND REMEDIATION ACTIVITIES

Italy Section E (Water supply; Sewerage, Waste Management and Remediation Activities) needs to be reanalysed since in some points it is obsolete.


Italy Intermediation of waste products to be added Type of change: New code Comment:

36 - Water collection, treatment and supply



37 - Sewerage

Hungary We suggest to move the manufactured products of wastes from 38 into “C” Manufacturing of NACE (e.g. compost, substitute fuels, biogaz, briquette, pellet etc.). The same way to move the manufacture of pellets, briquettes of sewage sludge from 37 (37.00.20) into “C” Manufacturing. Proposal: 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.


38 - Waste collection, treatment and disposal activities; materials recovery

Hungary We suggest to move the manufactured products of wastes from 38 into “C” Manufacturing of NACE (e.g. compost, substitute fuels, biogaz, briquette, pellet etc.). The same way to move the manufacture of pellets, briquettes of sewage sludge from 37 (37.00.20) into “C” Manufacturing. Proposal: 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.


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Portugal 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


Portugal Create a new class/group 38XX – 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.


38.21 - Treatment and disposal of non-hazardous waste

Lithuania 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???


F - CONSTRUCTION

France - What to do with the promoter-builder (by default, we classify it as a builder) Type of change: Blur boundaries Comment:

Lithuania Separate class in construction for manufacturing of modules. Type of change: New code Comment: Not possible to determine principal activity and evaluate value-added, but the main issue that this is should be considered as a part of the building (finished, just put and use as your fully equipped bathroom or toilet etc.

41 - Construction of buildings

Denmark Division 41 includes development of building projects, whereas division 42 does not, eg. outdoor sports facilities. We need somewhere to classify the project management etc., which is not performed by a third party. We’ve created our own in a sub class in 71.12


France Better describe classification criteria for divisions 43 and 41: what does "assume responsibility for a construction or renovation" mean?

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41.10 - Development of building projects

France - Better define the activity designated by "Development of building projects" Type of change: Complete explanatory notes Comment:

41.20 - Construction of residential and non-residential buildings

Finland The class includes "remodelling or renovating existing residential structures". Should there rather be a separate class for renovation activities, additions, and alterations?


France - Border between 43.99 and 41.20: many companies want to be in 43.99 even though they have declared "all construction works".


United Split 41.20: 41.2X Construction of residential buildings 41.2X Construction of all types of non-residential buildings


42 - Civil engineering



Italy Underwater construction works to be added (dredging, recovery and underwater archaeological excavations): - dredging works, rock and silt removal and other water-associated construction works - underwater works (by divers, frogmen or other techniques) and various hydraulic engineering works (...) CPA: 42.91.20 Construction works for coastal and port constructions, dams, locks and related hydro- mechanical structures Construction of wave attenuators


43 - Specialised construction activities

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France In the construction sector, the main criticism of the nacelles put forward by the actors is that it is not possible to clearly separate building and public works activities. In France, this separation structures construction companies and numerous surveys distinguish these two "sectors", in particular INSEE business surveys. This is not without its difficulties when using the NACE, in particular because of div.43 (Specialised construction activities), which often brings together the building and public works indiscriminately. On the other hand, I do not know if this specialisation of companies according to these two main types of activity is a French peculiarity.


France Better describe classification criteria for divisions 43 and 41: what does "assume responsibility for a construction or renovation" mean?


Italy Camera inspections in air ducts, water and gas pipes, and other liquids to be added Recovery of reinforced concrete to be added


Portugal Create a class 432X – Combined specialised construction activities We have enterprises who can make small works in different areas (electrical installation, plumbing, painting, joinery etc.) in the buildings


43.3 - Building completion and finishing

Lithuania Integrate all classes from this group into one class. Mostly all works are done by one unit. In Lithuania companies mostly do not specialize on one kind of finishing works they provide whole spectrum.


43.32 - Joinery installation



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43.99 - Other specialised construction activities n.e.c.

Denmark We suggest that it might be of value to split Bricklayers from 43.99 as they amount to more than 50% of the class.


France - Border between 43.99 and 41.20: many companies want to be in 43.99 even though they have declared "all construction works".


G - WHOLESALE AND RETAIL TRADE; REPAIR OF MOTOR VEHICLES AND MOTORCYCLES

Austria A new class combined for all distribution channels should be made (like 82.11 Combined office administrative service activities).


Austria Also many changes have taken place in the area of sales (Section G of NACE Rev.2). The distribution channels have changed during the last years: traditional shops are loosing importance and the sales via internet are expanding. Companies are classified according to the principal activity based on value added. Statistical data generated therefrom has therefore lost it‘s relevance. The added value from sales via internet is often higher than the added value from sales in the shop. Because of this, the classification from an enterprise is changed to sale via internet. The shifting of principal activities from retail sale to sale via internet suggests a disappearance of stores which is not necessarily true. The sale via internet should also be split. Whole sale via internet should be introduced.


Czech We consider introduction of new groups for support activities in section G (e.g. new groups for activities like discount portals, merchandising). Nowadays there exist many types of activities which have separated from the main activity and their aim is to facilitate the tasks of the unit which does the core activity. May be this could also concern other sections.


France Trade in frozen products: It is difficult to obtain the information needed to classify, either for the BR or even in the business surveys.


Spain Related to the ICT sector there has been an increase in online commerce compared to traditional commerce. On the one hand, retail trade is all included in a single code for any type of product. On the other hand, wholesale trade is disaggregated by product, for any form of sale.


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Switzerland Wholesale trade in raw materials It is an important activity in Switzerland (more than 8% of the GDP). We would like a class for this activity. We may also consider further details in the explanatory notes.


45 - Wholesale and retail trade and repair of motor vehicles and motorcycles

Austria We need a new class for whole sale with lamps and a new class for retail sale with lamps. Type of change: New code Comment:

Austria In whole sale we need more classes like in retail sale. Type of change: Split Comment:

France In wholesale trade, distinguish between forms of sale (parallel with retail trade). Type of change: Restructuring Comment:

Italy Mechatronics activities to be added Type of change: New code Comment:

45.20 - Maintenance and repair of motor vehicles

Lithuania Washing and polishing shouldn’t be the part of the repair, in NACE for all other goods and equipment, washing and cleaning separated from repairing and technical services.


46 - Wholesale trade, except of motor vehicles and motorcycles

Austria In whole sale we need more classes like in retail sale. Type of change: Split Comment:

Austria We need a new class for whole sale with lamps and a new class for retail sale with lamps. Type of change: New code Comment:

Czech In the area of sale via internet the difference between wholesale and retail sale is diminishing. Type of change: Comment:

Denmark We suggest a division of the wholesale trade to reflect the manufacturing Type of change: Restructuring Comment:

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France In wholesale trade, distinguish between forms of sale (parallel with retail trade). Type of change: Restructuring Comment:

Portugal Create new class 4667 –Wholesale of renewable energy equipment


46.1 - Wholesale on a fee or contract basis

France The reference to "including Internet wholesale auctions", which appears in the notes of group 46.1, is not included in the notes of other groups in division 46. Is wholesale trade via the Internet always considered to be carried out through an intermediary?


46.13 - Agents involved in the sale of timber and building materials

Estonia Please add to the description of this class that activities concerning wholesale on a fees or contract based to the forest cutting rights has to be classified into this class.


46.19 - Agents involved in the sale of a variety of goods

France Commercial agents / wholesale intermediaries: class 46.19 poses a number of problems. Registrants mainly want to be classified in 46.19 for reasons that are not admissible but are based both on the wording of the heading ("Agents involved in the sale of a variety of goods") and on the notes: they consider that if they sell more than one type of product, they should be classified in 46.19 (even if the product is real estate or food only).


46.3 - Wholesale of food, beverages and tobacco

Spain The methodology for classifying non-specialized trade in the case of wholesale trade is not accurate. There are problems between codes 46.39 and 46.90, the first one refers to a non-specialized trade but within group 46.3 which are clearly specialized classes.


46.34 - Wholesale of beverages

Poland The proposal of breaking down of class 46.34 on: Wholesale of alcoholic beverages Wholesale of non-alcoholic beverages

Type of change: Split Comment: The section off the sale of alcoholic beverages is aimed at collecting information about the activity of

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units involved in wholesale of alcoholic beverages. From the value of it is dependent the payment pay by the entrepreneurs. In connection with that constant monitoring this activity is legitimate.

46.39 - Non-specialised wholesale of food, beverages and tobacco

France Non-specialized food wholesale: The methodological rules cannot be applied as they stand, otherwise non-specialised food wholesale would be classified as 46.90 (instead of 46.39).


46.43 - Wholesale of electrical household appliances



46.46 - Wholesale of pharmaceutical goods



46.90 - Non-specialised wholesale trade

Denmark We suggest either renaming the class to Other wholesale n.e.c. or dividing class 46.90 into two classes, eg. Non-specialized wholesale and Specialized wholesale.


France Non-specialized food wholesale: The methodological rules cannot be applied as they stand, otherwise non-specialised food wholesale would be classified as 46.90 (instead of 46.39).


47 - Retail trade, except of motor vehicles and motorcycles

Austria We need a new class for whole sale with lamps and a new class for retail sale with lamps.

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Croatia Internet-based trade is fast-growing form of trade and it is necessary to foresee the possibility of allocating this form of trade to a separate class


Czech We propose to classify at first by the goods sold and thereafter by the type of sale (in stores, not in stores).


Czech In the area of sale via internet the difference between wholesale and retail sale is diminishing. Type of change: Comment:

Denmark There’s lots of interest in the development of internet retail, so we subdivided class 47.91 into 8 subclasses. A new class for each existing class (apart from 47.30) would result in about 30 new classes, which probably would be too many. A new Class for each relevant retail Group (apart from 47.3) would result in 6 new Classes.


Estonia Please restructure this division due to the increasing of retail trade via Internet, that needs to be separated from other activities.


Finland Most retailers, both specialised and non-specialised are active in e-commerce. It seems no longer valid to classify all e-commerce to the class 47.91.


France Retail sale of organic products in stores: strong demand for units to be distinguished in the classification. They insist on being classified in 47.29 even if the range of products sold is very wide (more than 5 classes).


France A new form of sale that is developing: retail trade "leaving on the spot" Type of change: New code Comment:

France - In retail trade: more finely classify the Internet commerce, which is starting to become important Type of change: Restructuring Comment:

France - Internet sales are booming, partly replacing retail sale in stores. However, NACE offers only a few categories for retail sale not in stores.

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Germany Due to the possibility to acquire much more clients via the Internet, it is assumed that in future more and more retailers will operate in a multichannel strategy. As a consequence there is currently no possibility for proper reporting of data for retail sale according to product groups, although there is a growing demand for such data. The shares of sales of retail sale in stores, the catalogue trade and accordingly the mail order trade, the teleshopping and the Internet shopping should be collected in addition to the type (range) of goods traded within the surveys. Proposal of change: Neglecting sales channel as a criterion for classification.


Hungary It would be necessary to follow the new trends, for example the turnover of web shops is growing fast. Proposal: to split 47.91 “Retail sale via mail order houses or via Internet” more details according to the goods typically sale via Internet. This would imply the complete re-structuring of 47 Retail trade. It would need more time to propose an exact new breakdown for “Retail trade”. Statistical domain experts would ask the opinions of the retail traders. Retail trade units often combine different types of trade channels, e.g. they have specialised stores and web shops and home delivery service, as well. So to select the principal activity of these units is difficult.


Italy Grow shop to be added Type of change: New code Comment:

Netherlands Retail trade is classified by type of sale outlet: shop, internet etc. However more and more units sell their goods via several types of outlet. Sale via shops and internet is often combined within one unit. This causes heterogeneity in the classes concerned: a low coverage and a low specialization ratio. The proposal is to base retail sale, like wholesale, only on the output, so the goods sold. With this choice the split in “good-classes”, following the goods sold, will be the same for the whole division 47, the same for sale via shops, internet etc.. This makes a consistent description of the retail sale by output, so products sold, possible.


Portugal Create a new class to: retail sale of commercial art galleries This is a proposal from our colleagues of “Cultural activities statistics”


47.22 - Retail sale of meat and meat products in specialised stores


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47.25 - Retail sale of beverages in specialised stores

Poland The proposal of breaking down of class 47.25 on: Retail sale of alcoholic beverages in specialized stores Retail sale of non-alcoholic beverages in specialized stores

Type of change: Split Comment: Section off the sale of alcoholic beverages is aimed at collecting information about turnover of alcoholic beverages. From the value of it is dependent the payment pay by the entrepreneurs. In connection with that constant monitoring this activity is legitimate.

47.26 - Retail sale of tobacco products in specialised stores

France - 4726 (Retail sale of tobacco products in specialised stores): as the turnover of the retail trade of tobacco products is poorly weighted in the process of determining the main activity (due to taxes), in practice there are few tobacco shops with this code.


47.30 - Retail sale of automotive fuel in specialised stores

France in practice, there are few petrol stations that have the code 47.30. Type of change: Other change Comment:

47.41 - Retail sale of computers, peripheral units and software in specialised stores

France Concerning the problems relating to the misidentification of the activities of digital actors, here is a list of classes in which we find easily recognizable companies with a strong cultural dimension (but today systematically ignored in economic or professional studies, in because of their NACE code): Class 47.41 (Retail sale of computers, peripheral units and software in specialised stores) includes retail sale of video game consoles; it might be wise to create a class "Retail sale of electronics games" Class 47.78 (Other retail sale of new goods in specialised stores) includes activities of commercial art galleries, which we would like to be able to isolate Class 47.91 (Retail sale via mail order houses or via Internet) includes the specialized retail trade of products via the Internet, and therefore contains Amazon, whose turnover is related to the sale of cultural products. It would seem wise to refine this class Class 61.30 (Satellite telecommunications activities) includes packages of television channels such as Canalplay Class 62.01 (Computer programming activities) contains companies which nevertheless have a cultural activity: for example Deezer (Odyssey music group), whose main activity is to offer music listening on the Internet, Art2M, whose main activity is the production and distribution of digital art works, or KazoArt, contemporary online art gallery Class 63.11 (Data processing, hosting and related activities) contains some online art gallery, such as Zeuxis Class 70.10 (Activities of head offices) includes Google France, which owns Youtube Class 73.11 (Advertising agencies) includes by misunderstanding some companies such as Spotify, whose main activity is listening to music on the Internet Class 74.90 (Other professional, scientific and technical activities n.e.c.) includes activities performed by agents or agencies on behalf of individuals and usually consisting of obtaining their recruitment in

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films, theatrical productions, other shows or sports events and to place books, plays, works of art, photos, etc. at publishers, producers, etc. Class 79.90 (Other reservation service and related activities) includes reservations for shows, which should be classified as 90.02 (Support activities to performing arts).


47.42 - Retail sale of telecommunications equipment in specialised stores

Malta This decreased popularity. To be amalgamated into NACE class 47.42. Type of change: Aggregation Comment:

47.43 - Retail sale of audio and video equipment in specialised stores

Malta This decreased popularity. To be amalgamated into NACE class 47.42. Type of change: Aggregation Comment:

47.52 - Retail sale of hardware, paints and glass in specialised stores

France Photovoltaic activities: how to classify retail trade without installation (47.78 or 47.52?) Can this growing activity be explicitly mentioned in the NACE notes? The same applies to the manufacture of photovoltaic panels.


47.63 - Retail sale of music and video recordings in specialised stores

France - The retail sale of music and video recordings in specialised stores is disappearing. Type of change: Restructuring Comment:



47.7 - Retail sale of other goods in specialised stores

Estonia Please remove under group 47.6 Proposal makes cultural economic activities extractible on 3 digit level of NACE according to ESSNet Culture final report and UNESCO FCS 2009.


Estonia Please add to the group a new class 4679: Other specialised wholesale activities not elsewhere classified

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47.75 - Retail sale of cosmetic and toilet articles in specialised stores

France - 47.75 (Retail sale of cosmetic and toilet articles in specialised stores): apart from the large retail chains, in practice the share of services 96.02 (beauty treatment) is predominant and most often leads to a change in classification.


47.78 - Other retail sale of new goods in specialised stores

Croatia Further breakdown of activities – it could be useful to separate some activities, e.g. activities of opticians


France Concerning the problems relating to the misidentification of the activities of digital actors, here is a list of classes in which we find easily recognizable companies with a strong cultural dimension (but today systematically ignored in economic or professional studies, in because of their NACE code): Class 47.41 (Retail sale of computers, peripheral units and software in specialised stores) includes retail sale of video game consoles; it might be wise to create a class "Retail sale of electronics games" Class 47.78 (Other retail sale of new goods in specialised stores) includes activities of commercial art galleries, which we would like to be able to isolate Class 47.91 (Retail sale via mail order houses or via Internet) includes the specialized retail trade of products via the Internet, and therefore contains Amazon, whose turnover is related to the sale of cultural products. It would seem wise to refine this class Class 61.30 (Satellite telecommunications activities) includes packages of television channels such as Canalplay Class 62.01 (Computer programming activities) contains companies which nevertheless have a cultural activity: for example Deezer (Odyssey music group), whose main activity is to offer music listening on the Internet, Art2M, whose main activity is the production and distribution of digital art works, or KazoArt, contemporary online art gallery Class 63.11 (Data processing, hosting and related activities) contains some online art gallery, such as Zeuxis Class 70.10 (Activities of head offices) includes Google France, which owns Youtube Class 73.11 (Advertising agencies) includes by misunderstanding some companies such as Spotify, whose main activity is listening to music on the Internet Class 74.90 (Other professional, scientific and technical activities n.e.c.) includes activities performed by agents or agencies on behalf of individuals and usually consisting of obtaining their recruitment in films, theatrical productions, other shows or sports events and to place books, plays, works of art, photos, etc. at publishers, producers, etc. Class 79.90 (Other reservation service and related activities) includes reservations for shows, which should be classified as 90.02 (Support activities to performing arts).


France Photovoltaic activities: how to classify retail trade without installation (47.78 or 47.52?) Can this growing activity be explicitly mentioned in the NACE notes? The same applies to the manufacture of photovoltaic panels.

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47.8 - Retail sale via stalls and markets

Estonia Please add to the division a new group “Retail sale of recreation goods in specialised stores” Please add to the new group new classes: 47.81 Retail sale of sporting equipment in specialised stores; 47.82 Retail sale of games and toys in specialised stores Proposal makes cultural economic activities extractible on 3 digit level of NACE according to ESSNet Culture final report and UNESCO FCS 2009.


Estonia Please add to the division a new group “Wholesale of cultural goods” Please add to the new group new classes: 46.81 Wholesale of porcelain and glass products; 46.82 Wholesale of watches and jewellery; 46.83 Wholesale of books and periodicals; 46.84 Wholesale of consumer electronics: CD and DVD players and recorders, stereo equipment. Video game consoles; 46.85 Wholesale of recorded audio and video tapes, CDs, DVDs; 46.86 Wholesale of musical instruments. Proposal makes cultural economic activities extractible on 3 digit level of NACE according to ESSNet Culture final report and UNESCO FCS 2009.


47.91 - Retail sale via mail order houses or via Internet

Finland Expression of “mail order houses” may be outdated Type of change: Complete explanatory notes Comment:

France Concerning the problems relating to the misidentification of the activities of digital actors, here is a list of classes in which we find easily recognizable companies with a strong cultural dimension (but today systematically ignored in economic or professional studies, in because of their NACE code): Class 47.41 (Retail sale of computers, peripheral units and software in specialised stores) includes retail sale of video game consoles; it might be wise to create a class "Retail sale of electronics games" Class 47.78 (Other retail sale of new goods in specialised stores) includes activities of commercial art galleries, which we would like to be able to isolate Class 47.91 (Retail sale via mail order houses or via Internet) includes the specialized retail trade of products via the Internet, and therefore contains Amazon, whose turnover is related to the sale of cultural products. It would seem wise to refine this class Class 61.30 (Satellite telecommunications activities) includes packages of television channels such as Canalplay Class 62.01 (Computer programming activities) contains companies which nevertheless have a cultural activity: for example Deezer (Odyssey music group), whose main activity is to offer music listening on the Internet, Art2M, whose main activity is the production and distribution of digital art works, or KazoArt, contemporary online art gallery Class 63.11 (Data processing, hosting and related activities) contains some online art gallery, such as Zeuxis Class 70.10 (Activities of head offices) includes Google France, which owns Youtube Class 73.11 (Advertising agencies) includes by misunderstanding some companies such as Spotify, whose main activity is listening to music on the Internet Class 74.90 (Other professional, scientific and technical activities n.e.c.) includes activities performed

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by agents or agencies on behalf of individuals and usually consisting of obtaining their recruitment in films, theatrical productions, other shows or sports events and to place books, plays, works of art, photos, etc. at publishers, producers, etc. Class 79.90 (Other reservation service and related activities) includes reservations for shows, which should be classified as 90.02 (Support activities to performing arts).


France Why classify "direct selling of fuel (heating oil, firewood, etc.), delivered to the customers premises" as 47.99 and not 47.91 when the buyer makes his choice on the basis of advertisements, catalogues, information provided on a website, models or any other means of advertising and places his order by mail, phone or over the Internet?


Ireland Online sales / internet sales would warrant to be on its own and then broken down into type of product sold online. As online sales grows and the number of enterprises in this area grow the detailed breakdown of the type of products sold is being lost. Eg a clothing company's turnover is now 50+% online it should be included in NACE 4791 we lose the information about what is being sold. Online sales should also be clear about whether it is services sold online eg taxi, takeaways versus products eg shoes. Retail sales ie to households versus business to business whether the financial transaction occurs online or whether it is just ordered online and paid seperately


Lithuania As a result of expanding online sales, it should be connect to stores or be more broadly grouped by product as well as the retail sale in specialized stores. Because the current breakdown does not reflect reality.


Sweden Suggestion to divide 47.91 (Retail trade not in stores, stalls or markets) into groups of different products (ex. food, clothes, etc.) when it comes to retail trade on the internet. Or, at least start to investigate how to class the internet trade.


Switzerland With this code we lose the aspect of the products (only the sales channel is considered). For example: • A company sells gardening items exclusively on internet. We lose the information of the product

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that the company sells. The activity of sale over the Internet should be based on the classification of the product and not the used channel. It would be important to have the same approach for wholesale as soon as the necessary adjustments have been made in the retail sale in order to have a certain homogeneity.


47.99 - Other retail sale not in stores, stalls or markets

France Why classify "direct selling of fuel (heating oil, firewood, etc.), delivered to the customers premises" as 47.99 and not 47.91 when the buyer makes his choice on the basis of advertisements, catalogues, information provided on a website, models or any other means of advertising and places his order by mail, phone or over the Internet?


H - TRANSPORTATION AND STORAGE

Denmark We would like to exclude Transport (Section H) from aggregation 4. Type of change: Restructuring Comment:

France Transportation: - Could the notes mention blood and organ transport? - How to classify a drone pilot without knowing his sector of activity (safety, transport of parcels, photography, film, ...)?


Spain NACE Rev.2 does not adequately collect activities that involve collaborative consumption. These activities have proliferated a lot in Sections such as transport and hospitality. The main problem lies in the unit offering the service, it is difficult to discriminate if they are individuals, households or companies. For example, transportation or accommodation (for short rentals), On the other hand, it is difficult to determine the activity of the platforms where these services are offered.


49 - Land transport and transport via pipelines

Portugal Create new class 49.33 – Interurban passenger transport, by road This is a proposal from our colleagues of “Transports statistics”


49.1 - Passenger rail transport, interurban

Lithuania Should be as in ISIC grouped by means of transport and then separated to the classes by passenger or

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freight transport. Lithuania is a small country and companies do not specializes in passenger or freight transport, provide all services. 49.1+49.2; 50.1+50.2; 50.3+50.4


49.2 - Freight rail transport

Lithuania Should be as in ISIC grouped by means of transport and then separated to the classes by passenger or freight transport. Lithuania is a small country and companies do not specializes in passenger or freight transport, provide all services. 49.1+49.2; 50.1+50.2; 50.3+50.4


49.20 - Freight rail transport

France Transport of blood and organs: should this activity be classified in 86.90 (activities of blood banks, sperm banks, transplant organ banks etc.) or in 49.20, 49.41, 50.20, 50.40, 51.21, 51.22 according to mode of transport?


49.31 - Urban and suburban passenger land transport

Netherlands The split of scheduled passenger land transport into urban/suburban (49.31) and regional (49.39) is not useful and arbitrary. Very often both kinds of transport are combines within the same unit and it is difficult to draw the line between the two. It is proposed to combine all scheduled passenger land transport into 49.31 and confine 49.39 to non- scheduled passenger land transport, like charters etc.


49.32 - Taxi operation

France 49.32 Taxi operation: The term "taxi" is problematic in France because it refers to a very specific corporation, to which operators of chauffeur-driven transport vehicles (VTCs) do not want to be assimilated (although they carry out the same activity).


Hungary This NACE class includes not only taxi services, but other passenger transport services by cars (see CPA subcategories). Proposal: to change the name of 49.32 for “Passenger transport services by cars”. The present name of 49.32 (Taxi operation) causes many problems in classification of businesses carried out this kind of activity. Proposal 2: Probably it is necessary to review the explanatory notes of the whole 49.3 “Other passenger land transport” in order to make clear the content of classes.


49.39 - Other passenger land transport n.e.c.

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Netherlands The split of scheduled passenger land transport into urban/suburban (49.31) and regional (49.39) is not useful and arbitrary. Very often both kinds of transport are combines within the same unit and it is difficult to draw the line between the two. It is proposed to combine all scheduled passenger land transport into 49.31 and confine 49.39 to non- scheduled passenger land transport, like charters etc.


49.4 - Freight transport by road and removal services

Italy Assembly of furniture (as in the case of IKEA) to be added Type of change: New code Comment:

49.41 - Freight transport by road



49.42 - Removal services

France Warehousing: - Improve the NACE notes to clarify the different types of storage that may exist > warehousing of goods (52.10) > warehousing of furniture related to removal services (49.42) > storage of physical archives > storage of digital archives > storage of scientific or medical data: blood, semen (other than for health purposes) or DNA or virus banks > Renting of self-storage facilities (68.20) - Limit with logistics activities: specify the border between 49.42 and 53.20 in case of delivery and installation of furniture and household equipment with unpacking or installation.

Type of change: Complete explanatory notes Comment: France Warehousing: - Improve the NACE notes to clarify the different types of storage that may exist > warehousing of goods (52.10) > warehousing of furniture related to removal services (49.42) > storage of physical archives > storage of digital archives > storage of scientific or medical data: blood, semen (other than for health purposes) or DNA or virus banks > Renting of self-storage facilities (68.20) - Limit with logistics activities: specify the border between 49.42 and 53.20 in case of delivery and installation of furniture and household equipment with unpacking or installation.


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49.5 - Transport via pipeline



49.50 - Transport via pipeline



50.1 - Sea and coastal passenger water transport



50.10 - Sea and coastal passenger water transport

Croatia New Classes: -transport of passengers over seas and coastal waters, whether scheduled or not by ferries and other passenger ships - Operation of cruisers - Operation of sightseeing boats, excursions and other passengers sea transport


50.2 - Sea and coastal freight water transport



50.20 - Sea and coastal freight water transport


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50.3 - Inland passenger water transport



50.4 - Inland freight water transport



50.40 - Inland freight water transport



51.21 - Freight air transport



52 - Warehousing and support activities for transportation

Portugal Create new classes 52.11 – Warehousing and storage of gas 52.12 – Warehousing and storage of frozen and refrigerated goods 52.19 – Warehousing and storage of other non-frozen goods (exc. gas) This is a proposal from our colleagues of “National Accounts statistics”


52.1 - Warehousing and storage

Netherlands A separate class within group 52.1 for distribution centres is proposed. Their activities go much further than only storage and consists of the redistribution of goods (order fulfilment) and activities to make

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that possible: bulk breaking, packaging, planning, logistics etc.


52.10 - Warehousing and storage



52.22 - Service activities incidental to water transportation



52.24 - Cargo handling

Finland Does this class include moving cargos on an industrial site? Many companies have outsourced such activity on their own production sites to a contractor.


53.20 - Other postal and courier activities



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I - ACCOMMODATION AND FOOD SERVICE ACTIVITIES

Spain NACE Rev.2 does not adequately collect activities that involve collaborative consumption. These activities have proliferated a lot in Sections such as transport and hospitality. The main problem lies in the unit offering the service, it is difficult to discriminate if they are individuals, households or companies. For example, transportation or accommodation (for short rentals), On the other hand, it is difficult to determine the activity of the platforms where these services are offered.


55 - Accommodation

Croatia Some new forms of accommodation have emerged that would need to be classified within section 55, e.g. “Robinson accommodation”. We suggest modification of explanatory notes that should clarify better the distinction between classes. Additional examples should be added.


Germany Classes in NACE Rev.2 that were created to differentiate the provision of accommodation are based on very different criteria (“daily cleaning and bed-making” vs. “cooking facilities or fully equipped kitchens”) which may be contradictory. Therefore this division should be reviewed. Proposal of change: Clear-cut criteria to distinguish the different types of provision of accommodation.


56.10 - Restaurants and mobile food service activities

Poland The proposal of breaking down of class 56.10 on: Restaurants and other non-mobile eating places Mobile eating places

Type of change: Split Comment: Proposed division is aimed at observation of the number of enterprises involved in this kind of activity, granting the help on the development of local enterprises (regional kitchens) etc.

56.21 - Event catering activities



J - INFORMATION AND COMMUNICATION

Finland The whole section needs a revision! Both structure and explanatory notes. Software has become an integral part of all animation, 3D and post-production.

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Game industry - how to classify it? Borderline between IT services and publishing? Note that the game industry has become significant in scale in our national economy.


France Could the omnipresence of indivisible wireline/wireless services not lead to the creation of a "Combined Telephony Services" code since there are other codes dedicated to combined services?


France Problems of sharing between: - IT / Telecom (in the corporate market, the borderline between the IT and telecoms world is becoming increasingly blurred) - Telecom / television. - Information technology / Publishing activities

Type of change: Blur boundaries Comment: Italy Section J (Information and Communication) is the part of the NACE Classification which probably needs the greatest improvements. Aspects of digitalisation and e-commerce should be examined in depth.


Spain The ICT sector is an emerging sector of the economy into all sector (see other points), and new activities are emerging in this field. For example, exploitation of web portals, e-sports, cybersecurity, community manager, influencer, bloggers, you tubers, etc.


58 - Publishing activities

Estonia Please add to the division a new group “Software publishing” Proposal makes cultural economic activities extractible on 3 digit level of NACE according to ESSNet Culture final report and UNESCO FCS 2009.




France The lease of intellectual property (77.40) excludes copyrights that are currently considered in divisions 58 and 59, with the production of originals or copies. However, it would be better either to isolate them within divisions 58 and 59, or to classify them with the other intellectual property products (77.40).


Germany Publishing activities in division 58 may also include the production of the published products like the

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production of software. Since production activities in general will contribute to the added value more than publishing activities, this seems to be contrary to the value added concept to be considered for all other parts of ISIC and NACE. Proposal of change: None. The approach should be reviewed.


Portugal Create a new class 58.15 – Publishing of photos, engraving, reproduction of works of art and other cultural products This is a proposal from our colleagues of “Cultural activities statistics”


58.12 - Publishing of directories and mailing lists

France Sharing between web portals (63.12), publishing of directories and mailing lists (58.12) (including digital) and marketplace activities needs to be clarified. The classification must depend on the main activity (search engine or display of lists or intermediary activity). Market place activities should be classified in trade section but they are not explicitly mentioned in the NACE. Market places' customers may be consumers or businesses, but this is most often retail trade: specific code expected: retail intermediary.


Netherlands Delete classes which are not very relevant like 58.12 Publishing of directories and mailing lists (not many enterprises, content not very clear) and 77.22 Rental of video tapes and disks (outdated and not many enterprises).


58.13 - Publishing of newspapers

France Publishing activities: Is the 58.13 / 58.14 distinction based on frequency of publication still appropriate when the weight of dematerialized editions has become very important (the website of a weekly magazine is updated daily? A remark concerning CPA but not NACE: regarding software publishing, CPA 58.29.1 concerning physical media is developed in CPA6, while CPA 58.29.4 concerning online software is not developed: it is a pity because online software is becoming the majority in recent sales, physical media are decreasing.


58.14 - Publishing of journals and periodicals

France Publishing activities: Is the 58.13 / 58.14 distinction based on frequency of publication still appropriate when the weight of dematerialized editions has become very important (the website of a weekly magazine is updated daily? A remark concerning CPA but not NACE: regarding software publishing, CPA 58.29.1 concerning physical media is developed in CPA6, while CPA 58.29.4 concerning online software is not developed: it is a pity because online software is becoming the majority in recent sales, physical media are decreasing.

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58.19 - Other publishing activities

France Large possible confusion between what actually falls within the scope of Web portals (63.12) and what is declared in the surveys. Non-intuitive classification of social networks in 58.19, video-sharing sites in 63.11.... In fact, many platforms actually use the 82.99 code (see Facebook, Uber). An update of the nomenclature notes would help in the classification.


58.2 - Software publishing

France Computer services: Many confusion between the purpose of the service offered by the company and the IT means used to develop it. The classic case is the ambiguity between "Software publishing" (58.2) and "Computer programming activities" (62.01). Another classic example is the GDS type of computerised travel reservation systems: ambiguity between 62 and 79. Computer maintenance is difficult to classify when it is inseparable from the software (combined service): is it part of the service related to software publishing (58.2) or is it technical assistance (62.02)?




Sweden Once again, we address the question of the difference between the two NACE Codes 58.2 (software publishing) and 62.01 (Computer programming activities). As discussed in the CIRCABC, a clearer distinction between the two need to be given in the explanatory text so that companies who develop software and makes it available thru a product disseminated, will have the correct code for their activities performed.


58.29 - Other software publishing


Type of change: Blur boundaries

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Comment:

Switzerland It is very difficult to distinguish this type of activities. Some IT companies carry out all activities without making distinctions: • 6201-Computer programming activities 6202-Computer consultancy activities 5829-Other software publishing It is the same for some telecommunication companies • 6110-Wired telecommunications activities 6120-Wireless telecommunications activities 6130-Satellite telecommunications activities Shouldn’t in these cases be defined, which activity is prioritized or shouldn’t be considered a grouping ? It is also possible that some activities will no longer exist.


59 - Motion picture, video and television programme production, sound recording and music publishing activities



59.11 - Motion picture, video and television programme production activities

France Streaming and video-on-demand: Such services can be classified into several divisions according to the characteristics of the company that produces the stream (59.11, 60.20, 61.10, 63.11...). The Voorburg group referred to this subject, considering that all of this is broadcasting via the Internet, i.e. only in div. 60. Wouldn't we benefit from promoting a single division for these service deliveries?


59.20 - Sound recording and music publishing activities

Sweden In CPA 2.1, ‘streaming services’ belongs to code 59.20, but for NACE Rev. 2 it belongs to code 63.11. Sweden suggest that a harmonization is done so that ’Sound recording and music publishing activities’ includes ‘Streaming services’ too.


60 - Programming and broadcasting activities

Denmark Update these to reflect the current situation. Is it, for example, necessary to keep 3 classes in division 61? We suggest merging these into one class.

Type of change: Aggregation

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Comment:



60.20 - Television programming and broadcasting activities



61 - Telecommunications



Finland Is the split between 61.1 Wired, 61.2 Wireless, 613 Satellite, and 619 Other any longer relevant or rather outdated?


Hungary Since 2008 many new technologies, services and products have been created. Proposal: to revise the structure and explanatory notes of 61, 62 and 63 divisions. Statistical domain experts consider necessary consultancies with IT service suppliers who know well the new trends and probably the expected changes.


61.10 - Wired telecommunications activities



Switzerland It is very difficult to distinguish this type of activities. Some IT companies carry out all activities without making distinctions: • 6201-Computer programming activities 6202-Computer consultancy activities

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5829-Other software publishing It is the same for some telecommunication companies • 6110-Wired telecommunications activities 6120-Wireless telecommunications activities 6130-Satellite telecommunications activities Shouldn’t in these cases be defined, which activity is prioritized or shouldn’t be considered a grouping ? It is also possible that some activities will no longer exist.


61.20 - Wireless telecommunications activities



61.30 - Satellite telecommunications activities

France Concerning the problems relating to the misidentification of the activities of digital actors, here is a list of classes in which we find easily recognizable companies with a strong cultural dimension (but today systematically ignored in economic or professional studies, in because of their NACE code): Class 47.41 (Retail sale of computers, peripheral units and software in specialised stores) includes retail sale of video game consoles; it might be wise to create a class "Retail sale of electronics games" Class 47.78 (Other retail sale of new goods in specialised stores) includes activities of commercial art galleries, which we would like to be able to isolate Class 47.91 (Retail sale via mail order houses or via Internet) includes the specialized retail trade of products via the Internet, and therefore contains Amazon, whose turnover is related to the sale of cultural products. It would seem wise to refine this class Class 61.30 (Satellite telecommunications activities) includes packages of television channels such as Canalplay Class 62.01 (Computer programming activities) contains companies which nevertheless have a cultural activity: for example Deezer (Odyssey music group), whose main activity is to offer music listening on the Internet, Art2M, whose main activity is the production and distribution of digital art works, or KazoArt, contemporary online art gallery Class 63.11 (Data processing, hosting and related activities) contains some online art gallery, such as Zeuxis Class 70.10 (Activities of head offices) includes Google France, which owns Youtube Class 73.11 (Advertising agencies) includes by misunderstanding some companies such as Spotify, whose main activity is listening to music on the Internet

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Class 74.90 (Other professional, scientific and technical activities n.e.c.) includes activities performed by agents or agencies on behalf of individuals and usually consisting of obtaining their recruitment in films, theatrical productions, other shows or sports events and to place books, plays, works of art, photos, etc. at publishers, producers, etc. Class 79.90 (Other reservation service and related activities) includes reservations for shows, which should be classified as 90.02 (Support activities to performing arts).




62 - Computer programming, consultancy and related activities

Austria The most changes in economic activities since 2008 have taken place in IT. There are a couple of new activities. Therefore the divisions 62 and 63 of NACE Rev.2 should be revised.


Austria A new class should be made as well, where the provision of a combination of miscellaneous IT activities is classified (like 82.11 Combined office administrative service activities)






Hungary Since 2008 many new technologies, services and products have been created. Proposal: to revise the structure and explanatory notes of 61, 62 and 63 divisions. Statistical domain experts consider necessary consultancies with IT service suppliers who know well the new trends and

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probably the expected changes.


Lithuania Programming services developing fast and becomes a big part of the business and companies often specialize in specific applications: - Business management system; - Accounting programs; - IT security assurance; - E-commerce solutions; - Data bases (DB) activities; etc. Often, users are requesting statistics for new groups of activities


Slovenia In the field of Information and Communications Technology we are faced with the demand of how many companies offer digital platforms, e.g. GoOpti, Uber, etc., which are now classified in NACE 63.12 Web portals. For such companies, a new activity should be created. Due to the development of the area, it would be necessary to review all the activities in divisions 62 Computer programming, consultancy and related activities and 63 Information service activities.


62.01 - Computer programming activities

France Concerning the problems relating to the misidentification of the activities of digital actors, here is a list of classes in which we find easily recognizable companies with a strong cultural dimension (but today systematically ignored in economic or professional studies, in because of their NACE code): Class 47.41 (Retail sale of computers, peripheral units and software in specialised stores) includes retail sale of video game consoles; it might be wise to create a class "Retail sale of electronics games" Class 47.78 (Other retail sale of new goods in specialised stores) includes activities of commercial art galleries, which we would like to be able to isolate Class 47.91 (Retail sale via mail order houses or via Internet) includes the specialized retail trade of products via the Internet, and therefore contains Amazon, whose turnover is related to the sale of cultural products. It would seem wise to refine this class Class 61.30 (Satellite telecommunications activities) includes packages of television channels such as Canalplay Class 62.01 (Computer programming activities) contains companies which nevertheless have a cultural activity: for example Deezer (Odyssey music group), whose main activity is to offer music listening on the Internet, Art2M, whose main activity is the production and distribution of digital art works, or KazoArt, contemporary online art gallery Class 63.11 (Data processing, hosting and related activities) contains some online art gallery, such as Zeuxis Class 70.10 (Activities of head offices) includes Google France, which owns Youtube Class 73.11 (Advertising agencies) includes by misunderstanding some companies such as Spotify, whose main activity is listening to music on the Internet Class 74.90 (Other professional, scientific and technical activities n.e.c.) includes activities performed by agents or agencies on behalf of individuals and usually consisting of obtaining their recruitment in films, theatrical productions, other shows or sports events and to place books, plays, works of art, photos, etc. at publishers, producers, etc. Class 79.90 (Other reservation service and related activities) includes reservations for shows, which

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should be classified as 90.02 (Support activities to performing arts).








62.02 - Computer consultancy activities


Type of change: Blur boundaries

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Comment:



63 - Information service activities

Austria The most changes in economic activities since 2008 have taken place in IT. There are a couple of new activities. Therefore the divisions 62 and 63 of NACE Rev.2 should be revised.




Estonia Please add to the division a new group “News agency activities” Proposal makes cultural economic activities extractible on 3 digit level of NACE according to ESSNet Culture final report and UNESCO FCS 2009.


Hungary Since 2008 many new technologies, services and products have been created. Proposal: to revise the structure and explanatory notes of 61, 62 and 63 divisions. Statistical domain experts consider necessary consultancies with IT service suppliers who know well the new trends and probably the expected changes.


Italy Smart metering activities to be added The activity of providing on-line services to pay fines, bills (telephone, energy, ..), concert tickets, train tickets and so on to be added; such activity is generally undertaken by shops selling tobacco products. In Italy these services are identified with the neologism “Chiosco elettronico”


Slovenia In the field of Information and Communications Technology we are faced with the demand of how

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many companies offer digital platforms, e.g. GoOpti, Uber, etc., which are now classified in NACE 63.12 Web portals. For such companies, a new activity should be created. Due to the development of the area, it would be necessary to review all the activities in divisions 62 Computer programming, consultancy and related activities and 63 Information service activities.


63.11 - Data processing, hosting and related activities

France Concerning the problems relating to the misidentification of the activities of digital actors, here is a list of classes in which we find easily recognizable companies with a strong cultural dimension (but today systematically ignored in economic or professional studies, in because of their NACE code): Class 47.41 (Retail sale of computers, peripheral units and software in specialised stores) includes retail sale of video game consoles; it might be wise to create a class "Retail sale of electronics games" Class 47.78 (Other retail sale of new goods in specialised stores) includes activities of commercial art galleries, which we would like to be able to isolate Class 47.91 (Retail sale via mail order houses or via Internet) includes the specialized retail trade of products via the Internet, and therefore contains Amazon, whose turnover is related to the sale of cultural products. It would seem wise to refine this class Class 61.30 (Satellite telecommunications activities) includes packages of television channels such as Canalplay Class 62.01 (Computer programming activities) contains companies which nevertheless have a cultural activity: for example Deezer (Odyssey music group), whose main activity is to offer music listening on the Internet, Art2M, whose main activity is the production and distribution of digital art works, or KazoArt, contemporary online art gallery Class 63.11 (Data processing, hosting and related activities) contains some online art gallery, such as Zeuxis Class 70.10 (Activities of head offices) includes Google France, which owns Youtube Class 73.11 (Advertising agencies) includes by misunderstanding some companies such as Spotify, whose main activity is listening to music on the Internet Class 74.90 (Other professional, scientific and technical activities n.e.c.) includes activities performed by agents or agencies on behalf of individuals and usually consisting of obtaining their recruitment in films, theatrical productions, other shows or sports events and to place books, plays, works of art, photos, etc. at publishers, producers, etc. Class 79.90 (Other reservation service and related activities) includes reservations for shows, which should be classified as 90.02 (Support activities to performing arts).




France Large possible confusion between what actually falls within the scope of Web portals (63.12) and what is declared in the surveys. Non-intuitive classification of social networks in 58.19, video-sharing sites in 63.11.... In fact, many platforms actually use the 82.99 code (see Facebook, Uber).

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An update of the nomenclature notes would help in the classification.


Sweden In CPA 2.1, ‘streaming services’ belongs to code 59.20, but for NACE Rev. 2 it belongs to code 63.11. Sweden suggest that a harmonization is done so that ’Sound recording and music publishing activities’ includes ‘Streaming services’ too.


63.12 - Web portals



France Sharing between web portals (63.12), publishing of directories and mailing lists (58.12) (including digital) and marketplace activities needs to be clarified. The classification must depend on the main activity (search engine or display of lists or intermediary activity). Market place activities should be classified in trade section but they are not explicitly mentioned in the NACE. Market places' customers may be consumers or businesses, but this is most often retail trade: specific code expected: retail intermediary.


K - FINANCIAL AND INSURANCE ACTIVITIES

Spain The Financial Section describes more the classification of the products than the activities of the management companies. The classification could be revised in this sense, that is, to classify more the activities and not so much the products. Review the financial activities that may require a specific heading in which to integrate the new operating agents in the so-called Financial Technology or Fintech.


United Align Section K (financial and insurance activities) with the DGI-2 expansion of the G20 Sectoral Accounts.

Type of change: Other change Comment: Section K would benefit from having a more granular breakdown than at present. As a minimum, the industry breakdown should be comparable with the breakdown proposed for the G20 Sectoral Accounts expansion of the financial sector and that used in the FSB Shadow Banking exercise. Section K (financial and insurance activities) should as a minimum be comparable with that proposed as part of the DGI-2 expansion of the G20 Sectoral Accounts (additional financial sector sub- sectors/industries)

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The existing industry breakdown of Section K (financial and insurance activities) is far less granular than many of the post-financial crisis requirements for information on the financial sector. Recent enhancements to international data requirements stemming from the Data Gaps Initiatives focus on far more data granularity especially in relation to the activities of the shadow banking sector. Domestic data collections are also more granular and reflect policy needs that go beyond the minimal requirements of the existing NACE requirements; this includes the additional granularity included as part of the UK’s Enhanced Financial Accounts.

64 - Financial service activities, except insurance and pension funding

Denmark We would like a separate class for enterprises which have sold of their production of goods/services, but still are ‘active’ managing their own money. They like to choose 66.30, so we have to re classify them. At the moment we shift them to 64.99.


64.2 - Activities of holding companies

Czech Proposal on change within the class 64.2. The proposed structure refers to the NACE 64.2 specification. The current definition of NACE 64.2 does not adequately describe the existing range of types of holding and similar companies. Proposed structure: 64.2 Activities of holding and similar companies 64.21 Activities of holding companies – superior parent entities This class includes activities of holding companies that are superior parent entities that hold controlling levels of equity of a group of subsidiaries. The holding companies do not provide any other service to the businesses in which the equity is held, do not have employment or turnover. 64.22 Activities of sub holding companies – parents of subgroup This class includes activities of holding companies that are only the head of a subgroup of subsidiaries and hold controlling levels of equity of a subgroup of subsidiaries. The holding companies do not provide any other service to the businesses in which the equity is held, do not have employment or turnover. 64.23 Activities of companies similar to holding companies This class includes activities of units that hold non-controlling level of equity. These units do not provide any other service to the businesses in which the equity is held, do not have employment or turnover.


64.20 - Activities of holding companies

France Differentiate 64.20 and 70.10: is it possible to insert in the methodological notes the classification trees and guidelines developed by the TF HO-HS?


United Adopt an alphanumeric approach to identify holding companies by adding a suffix of 'H' to existing industries.

Type of change: Other change Comment: Industry 64.2 (activities of holding companies) comprises all holding companies irrespective of the industry of their subsidiary corporation. In many instances, capital raised by the holding company is ultimately passed through to the subsidiary corporation and a more granular breakdown of holding

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companies will facilitate a better reallocation of capital to the ultimate beneficiary industry. To comply with ESA10 requirements, the Bank still need to allocate the holding company to Sector S.127 - Captive financial institutions and money lenders. Having the proposed suffix to identify holding company by the industry of their subsidiary will enable compilation of data both for monetary analysis and compliance with ESA10 requirements.

64.30 - Trusts, funds and similar financial entities

Denmark Clarification of the border between 6499 and 6430 Type of change: Blur boundaries Comment:

United Split class 64.30: 64.3x: Open End Investment Funds 64.3x: Close End Investment Funds 64.3x: Venture and Development Capital Companies and Funds 64.3x: Real Estate Investment Trusts (REITs)

Type of change: Split Comment: Open and Closed End Investment Funds: The Financial Stability Board’s monitors Global Shadow Banking and two areas monitored are leverage and potential runs. The proposed changes relate to 64.3 Trusts, Funds and Similar Financial Entities Close end funds typically are able to borrow funds more easily than Open end funds and so the leverage distinction between them is important. Furthermore since Close end funds are closed (i.e. share issued only once) there is no danger of the fund suffering liquidity problems as shares are only traded on a secondary market. Open end funds by contrast must add / retire share (units) on demand and are therefore susceptible to runs. Dividing investment funds between Open and Closed also enables Money Market Funds to be easily added to Open end funds. Venture and Development Capital Companies and Funds are important potential contributors to economic activity but are also somewhat risky compared to more traditional funds and investments. It is therefore proposed to separately identify these type of funds via a dedicated NACE class within 64.3. Having a dedicated NACE class would also assist with measuring Shadow Banking. Real Estate Investment Trusts (REITs): The Financial Stability Board, which monitors Global Shadow Banking, requires FSB member countries to submit a template once per year. In order to measure Shadow Banking that template requests separate information on REITs, Real Estate Funds and Equity / Mortgage funds / REITs.

64.9 - Other financial service activities, except insurance and pension funding

United Specific 4 digit class for Central Clearing Counterparties (CCPs), within group 64.9 Type of change: New code Comment: Currently there isn’t any explicit mention of CCPs in NACE Rev 2. A dedicated NACE class for CCP would be in line with the ESA 2010 S.125 financial sector.

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64.92 - Other credit granting

United Create a class for each of the inclusions within 64.92: 64.9x Granting of Consumer Credit 64.9x Credit Granting for Home purchase by Specialised Non-Depository Institutions 64.9x International Trade Financing 64.9x Provision of Long-Term Finance to Industry by Industrial Banks 64.9x Money Lending Outside the Banking System 64.9x Pawnshops and Pawnbrokers - primary business lending money 64.9x Money Lenders 64.9x Student Lending 64.9x Other Credit Granting

Type of change: New code Comment: Non-Bank Credit Intermediation is the activity based definition used by the Financial Stability Board to measure Shadow Banking. It is important to be able to identify different types of credit granting so that Shadow Banking risks can be accurately assessed.

64.99 - Other financial service activities, except insurance and pension funding n.e.c.

Denmark Clarification of the border between 6499 and 6430 Type of change: Blur boundaries Comment:

United Securitisation to be specifically mentioned in the inclusions for 64.99 Type of change: Complete explanatory notes Comment: ESA 2010 S.125 contains Financial Vehicle Corporations that engage in Securitisation transactions. Euro area countries already report FVCs data to the ECB. There isn’t any mention of Securitisation in NACE Rev 2. The FSB as part of its shadow banking monitoring activities requires data on Securitisation.

65.12 - Non-life insurance

Netherlands Investigate if it is possible to create a separate class for health insurances, so to split 65.12 Non-life insurance into two classes. That would be interesting for describing all health care expenses.


68 - Real estate activities

Hungary We suggest to split the 3-digit NACE groups into 2 classes as follows: - residential buildings - not-residential buildings.

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Type of change: Split Comment: Reasoning: Economic units classified here usually are specialized for residential or non-residential buildings. And users needs separate statistical data on the level of NACE.

68.1 - Buying and selling of own real estate

Malta The ambiguity of NACE 68.1 should be resolved. A clearer definition is required. Type of change: Complete explanatory notes Comment:

68.20 - Rental and operating of own or leased real estate

Denmark Split 6820 into two classes; one class for residential buildings and one for non-residential. Type of change: Split Comment:



Lithuania Differentiate short-term rental and accommodation services for dwellings. Type of change: Split Comment:

68.31 - Real estate agencies

France - Real estate agencies (68.31): because of the word "agency" in the wording, we sometimes have difficulty to justify the classification of "independent" estate agents in this class.


M - PROFESSIONAL, SCIENTIFIC AND TECHNICAL ACTIVITIES

Switzerland Today, we notice that the same enterprise / unit covers many activities go hand in hand. Many design companies (7410-Specialised design activities) also advertise (7311- Advertising agencies). It is the same for transport of freight companies. Nowadays companies offer global logistics services / solutions including both transport and storage. We noticed a general trend, that companies perform multiple simultaneous activities without a predominant one. Explanatory notes should provide recommendations for these cases and tell which activity takes priority.


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69 - Legal and accounting activities

Italy Civil mediation activities to be added Type of change: New code Comment:

69.10 - Legal activities

Croatia Further breakdown of activities – it could be useful to separate activities of public notaries and attorneys: - Activities of lawyers (legal advisory and representation activities) - Activities of notaries (notarial activities) - Other legal activities


France In class 69.10, it would be desirable to distinguish the various legal activities (lawyers, notaries, bailiffs, auctioneers ...). The turnover of the class amounts to 22 billion euros in France.


69.20 - Accounting, bookkeeping and auditing activities; tax consultancy



70 - Activities of head offices; management consultancy activities

Italy Monitoring of development projects to be added Activities of Energy Saving Companies (ESCO) to be added Consulting and management of social pages (Facebook, Instagram) for companies to be added Relocation Coach to be added


70.10 - Activities of head offices

France Differentiate 64.20 and 70.10: is it possible to insert in the methodological notes the classification trees and guidelines developed by the TF HO-HS?


France Concerning the problems relating to the misidentification of the activities of digital actors, here is a list of classes in which we find easily recognizable companies with a strong cultural dimension (but today systematically ignored in economic or professional studies, in because of their NACE code): Class 47.41 (Retail sale of computers, peripheral units and software in specialised stores) includes retail sale of video game consoles; it might be wise to create a class "Retail sale of electronics games" Class 47.78 (Other retail sale of new goods in specialised stores) includes activities of commercial art

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galleries, which we would like to be able to isolate Class 47.91 (Retail sale via mail order houses or via Internet) includes the specialized retail trade of products via the Internet, and therefore contains Amazon, whose turnover is related to the sale of cultural products. It would seem wise to refine this class Class 61.30 (Satellite telecommunications activities) includes packages of television channels such as Canalplay Class 62.01 (Computer programming activities) contains companies which nevertheless have a cultural activity: for example Deezer (Odyssey music group), whose main activity is to offer music listening on the Internet, Art2M, whose main activity is the production and distribution of digital art works, or KazoArt, contemporary online art gallery Class 63.11 (Data processing, hosting and related activities) contains some online art gallery, such as Zeuxis Class 70.10 (Activities of head offices) includes Google France, which owns Youtube Class 73.11 (Advertising agencies) includes by misunderstanding some companies such as Spotify, whose main activity is listening to music on the Internet Class 74.90 (Other professional, scientific and technical activities n.e.c.) includes activities performed by agents or agencies on behalf of individuals and usually consisting of obtaining their recruitment in films, theatrical productions, other shows or sports events and to place books, plays, works of art, photos, etc. at publishers, producers, etc. Class 79.90 (Other reservation service and related activities) includes reservations for shows, which should be classified as 90.02 (Support activities to performing arts).


Hungary Multinational companies usually outsource the ancillary activities to SSC registered in another country and possessing educated/qualified and cheap labour/personnel. SSC businesses usually carry out ancillary activities e.g. accounting, HR, customer service, marketing, IT development etc. The activity of SSC businesses is heterogeneous so it is difficult to choose the right NACE code for principal activity. For example: accounting: 69.20.23, HR: 70.22.14; programming: 62.03.11; website design: 63.11.12; catalogue, poster: 73.11.11 etc. We have several options to classify SSC into an appropriate NACE code. 70.10 “Activities of head offices” 82.11 “Combined office administrative service activities” We have a dilemma whether the activity of SSC is administrative or professional activity? 70.2 “Management consultancy activities” Where to classify SSC in the present NACE? Some SSCs carry out their activity not for “mother company” within the same multinational company”, but for other companies (outside of multinational company). Where do you classify this SSC? Proposal: to make more precise the explanatory notes of NACE 82.11, 70.10.


United A class level breakdown to indicate the main activity of the group for which the head office is acting: 70.1X: Activities of agricultural head offices

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70.1X: Activities of production head offices 70.1X: Activities of construction head offices 70.1X: Activities of distribution head offices 70.1X: Activities of financial services head offices 70.19: Activities of other head offices Alternatively: 70.1x: Activities of non-financial corporations head offices 70.1x: Activities of financial corporations head offices etc.

Type of change: Split Comment: ESA 2010 (2.14a) states: Head offices are allocated to the dominant non-financial corporations sector of their subsidiaries, unless all or most of their subsidiaries are financial corporations, in which case they are treated as financial auxiliaries (S.126) in the financial corporations sector. Having distinct NACE codes for head offices managing groups of different activities would make it simpler to allocate activity to the correct institutional sector and assist with survey sampling and data collection. 71 - Architectural and engineering activities; technical testing and analysis

Estonia Please add to the division a new group “Architectural activities” Proposal makes cultural economic activities extractible on 3 digit level of NACE according to ESSNet Culture final report and UNESCO FCS 2009.


France 74.90 vs 71 Despite the presence of a fairly detailed explanatory note, classification issues are recurrent. Shouldn't we have in the same class the activities of quantity surveyors ant the activities of the construction economists, And both in division 71 (Architectural and engineering activities; technical testing and analysis)? Similarly, environmental consulting (74.901) is often integrated into construction engineering projects; moreover, geophysical and geological studies are in 71 and often go hand in hand with "environmental consulting".


France The limits between engineering and research: > when does a research activity (72) become an engineering activity (71)? > how to draw the line between research (72) and activities to promote propagation, growth and output of animals (01.62)?


Italy Domotics activities to be added

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71.11 - Architectural activities

France - Frontier between 71.11/71.12 and 74.90 for project management, assistance with project management, building site planning: classification is often difficult to carry out.


71.12 - Engineering activities and related technical consultancy





Slovenia We believe that it is necessary to reconsider the classes NACE 41.10 Development of building projects and 71.12 Engineering activities and related technical consultancy - to define which activities are included in those two classes, because it is difficult to distinguish between construction and engineering activities in practice.


71.20 - Technical testing and analysis

Poland The proposal of breaking down of class 71.20 on: Testing and measuring the quality of food Other technical testing and analysis

Type of change: Split Comment: Due to the specific of testing and analysis of the quality of food, the proposal of isolating the independent class for such activity. This activity includes mainly testing of animals before the slaughter and their meats after the slaughter, which are conducted under veterinary supervision in slaughterhouse.

Slovenia NACE 71.20 Technical testing and analysis should include: - operation of forensic laboratories Type of change: Complete explanatory notes Comment:

72 - Scientific research and development

France The classification of prototype manufacturing: classification of prototype manufacturing: at the

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borderline between industrial activities and Scientific research and development (div.72), or even div.74.


France On the part of the Ministry of Research, we focussed on Division 72, entitled "Scientific Research and Development" and its two groups 72.1 and 72.2, which are supposed to make it possible to distribute all areas of research, on the one hand in Research and experimental development on natural sciences and engineering (72.1) and, on the other hand, in Research and experimental development on social sciences and humanities (72.2). This seems to us to be very restrictive, as are the only three classes that are then distinguished: Research and experimental development on biotechnology (72.11), Other research and experimental development on natural sciences and engineering (72.19) and Research and experimental development on social sciences and humanities (72.20). Moreover, it seems strange to us that the nomenclature focuses on R&D in biotechnology, which represents only about 10% of the research carried out in companies. As far as research organizations are concerned, the quasi-dichotomy between R&D in the physical and natural sciences and R&D in the humanities and social sciences makes the classification of generalist organizations, such as the CNRS or the IRD, as our main financial organization, the ANR, difficult (it should be noted that the CNRS, like the IRD are coded in 7219... and the ANR in 7220!) It is also surprising that areas of research such as health, environment or agriculture, for example, are not more visible in the current nomenclature. The Frascati Manual 2015, which provides guidelines for collecting and reporting data on research and experimental development, prepared by OECD member countries, identifies three types of R&D: basic research, applied research and experimental development. The Manual also provides, in the new French version published in 2016, a classification of R&D fields into six categories (Natural Sciences, Engineering and Technology, Medical and Health Sciences, Agricultural and Veterinary Sciences, Social Sciences and Human Sciences and Arts) and forty-two subcategories. With regard to this classification of R&D fields, the authors also state: "In view of the current evolution of the ways in which R&D is carried out and the gradual emergence of new fields, the OECD classification of research and development fields will be subject to continuous review following the publication of this version of the Manual". The Inter-ministerial Mission for Research and Higher Education (MIRES) has 9 research programmes, which could also allow for a more precise classification of the different research areas (http://www.enseignementsup-recherche.gouv.fr/cid61606/la-mission-interministerielle-recherche-et- enseignement-superieur-mires.html): Program142 - Higher education and agricultural research Program150 - Postgraduate Training and University Research Program172 - Multidisciplinary scientific and technological research Program186 - Cultural research and scientific culture (Ministry of Culture and Communication) Program187 - Research in the field of environmental and resource management Program190 - Research in the fields of sustainable energy, development and planning

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Program191 - Dual Research Program192 - Research and higher education in economic and industrial matters Program193 - Space Research

Type of change: Restructuring Comment: France The limits between engineering and research: > when does a research activity (72) become an engineering activity (71)? > how to draw the line between research (72) and activities to promote propagation, growth and output of animals (01.62)?


Italy Clinical Monitor to be added Type of change: New code Comment:

Poland Moreover, we shouldn’t forget to introduce to the revised NACE the new class in the scope of chapter 72 concerning scientific research and development in the field of the interdisciplinary sciences which was isolated during the last revision of CPA Rev. 2.1.


Romania In order to ensure the consistency of the future NACE with the current CPA Ver.2.1, we believe that some changes have to be done in the field of research and development (division 72) such that the correspondence/harmonization between classifications to be achieved (i.e.: 7200 CPA Ver.2.1 code = ???? NACE code).


Sweden In CPA 2.1, the new code 72.00 (Interdisciplinary research and experimental development services), should have its equivalent in NACE.


72.11 - Research and experimental development on biotechnology

Denmark What’s the point of 72.11? It’s related to medical research so it could easily be merged with the current 72.19.


72.19 - Other research and experimental development on natural sciences and engineering

Denmark What’s the point of 72.11? It’s related to medical research so it could easily be merged with the current 72.19.


United Split 72.19:

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72.12 Research and development on natural sciences 72.13 Research and development on engineering and technology 72.14 Research and development on medical sciences 72.15 Research and development on agricultural sciences 72.16 Interdisciplinary research and development, predominantly on natural sciences and engineering

Type of change: Split Comment: To better measure the Life Sciences sector.

73.11 - Advertising agencies

France Design and advertising: advertising printing companies want to be classified as advertising (18.12 vs. 73.11). These companies estimate that they design the advertisements (perhaps it is necessary to better describe in 73.11 the design part of the advertising campaign)

Type of change: Complete explanatory notes Comment: France Concerning the problems relating to the misidentification of the activities of digital actors, here is a list of classes in which we find easily recognizable companies with a strong cultural dimension (but today systematically ignored in economic or professional studies, in because of their NACE code): Class 47.41 (Retail sale of computers, peripheral units and software in specialised stores) includes retail sale of video game consoles; it might be wise to create a class "Retail sale of electronics games" Class 47.78 (Other retail sale of new goods in specialised stores) includes activities of commercial art galleries, which we would like to be able to isolate Class 47.91 (Retail sale via mail order houses or via Internet) includes the specialized retail trade of products via the Internet, and therefore contains Amazon, whose turnover is related to the sale of cultural products. It would seem wise to refine this class Class 61.30 (Satellite telecommunications activities) includes packages of television channels such as Canalplay Class 62.01 (Computer programming activities) contains companies which nevertheless have a cultural activity: for example Deezer (Odyssey music group), whose main activity is to offer music listening on the Internet, Art2M, whose main activity is the production and distribution of digital art works, or KazoArt, contemporary online art gallery Class 63.11 (Data processing, hosting and related activities) contains some online art gallery, such as Zeuxis Class 70.10 (Activities of head offices) includes Google France, which owns Youtube Class 73.11 (Advertising agencies) includes by misunderstanding some companies such as Spotify, whose main activity is listening to music on the Internet Class 74.90 (Other professional, scientific and technical activities n.e.c.) includes activities performed by agents or agencies on behalf of individuals and usually consisting of obtaining their recruitment in films, theatrical productions, other shows or sports events and to place books, plays, works of art, photos, etc. at publishers, producers, etc. Class 79.90 (Other reservation service and related activities) includes reservations for shows, which should be classified as 90.02 (Support activities to performing arts).


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74 - Other professional, scientific and technical activities

France The classification of prototype manufacturing: classification of prototype manufacturing: at the borderline between industrial activities and Scientific research and development (div.72), or even div.74.


Italy 3D Printing to be added when it is not intended as manufacturing but relates to the production of three-dimensional models (74.10 Other specialised design services) Services intermediation (web service contracts stipulation) to be added Pension insurance advisory activities to be added “Tariff consultancy” for telephone, energy, gas and insurance to be added E-procurement activities to be added Activities of “signalling/recommending” customers (lists of possible customers) to others to be added Activities of sales representative for pharmaceutical products to be added


74.10 - Specialised design activities

Croatia Further breakdown of activities – it could be useful to separate activities into several classes: - Activities of industrial design - Activities of interior design - Activities of graphic design - Other design activities


France Graphic designers want to be classified in 18.13: could the notes better describe 18.13 or quote the graphic designer in 74.10?


France Design vs architecture : explicit mention of interior design activities ("architecture d'intérieur") in Class 74.10 notes would reduce litigation (74.10 vs. 71.11)


74.20 - Photographic activities

France - Artistic creation (90.03): artists in general wish to be classified in 90.03 (To top it all off, in some cases, simply having an activity code 90.03 "proves" the artistic nature of their activity! and in some devices, this code is required to benefit from measures reserved for artists). On this subject, these remarks are similar to those made by statisticians from the Ministry of Culture. > suggestion: class 74.20 for example, specify in the notes that this class includes author-photographers and artist-photographers.


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74.90 - Other professional, scientific and technical activities n.e.c.

France 74.90 vs 71 Despite the presence of a fairly detailed explanatory note, classification issues are recurrent. Shouldn't we have in the same class the activities of quantity surveyors ant the activities of the construction economists, And both in division 71 (Architectural and engineering activities; technical testing and analysis)? Similarly, environmental consulting (74.901) is often integrated into construction engineering projects; moreover, geophysical and geological studies are in 71 and often go hand in hand with "environmental consulting".




France Other support services (82.99) amount to € 29 billion in terms of turnover. It would be better to break up the activities or to reclassify them. Similarly, the other specialized, scientific and technical activities (74.90) constitute a catch-all item, as well as "other personal services n.e.c." (96.09) which brings together very heterogeneous activities (€ 2 billion in France).


75.00 - Veterinary activities

Slovenia We propose establishing of new classes for Veterinary activities (now class 75.00) NACE 75.00 Veterinary activities 75.10 Livestock (breeding in agriculture) 75.20 Aquaculture 75.30 Other domestic animals or pets The emphasis is on dividing costs for livestock in agriculture and for domestic animals, which do not have anything in common with farming in agriculture.


N - ADMINISTRATIVE AND SUPPORT SERVICE ACTIVITIES

France Handymen services: the CPA notes (81.21.11) allow to classify them unambiguously in 81.21. However, the companies that provide these services do not recognize themselves in the wordings "Administrative and support services"(sect.N) or "Services to buildings and landscape" (div.81), which refer to services provided to businesses rather than individuals or households.


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77 - Rental and leasing activities

Italy Design, manufacture and rental of flowers, plants and floral compositions (for weddings and conventions) to be added


77.11 - Rental and leasing of cars and light motor vehicles

Croatia Separation the activities of leasing and renting cars in two classes: - Renting of cars and light motor vehicles - Leasing of cars and light motor vehicles (further clarification in additional document)


77.21 - Rental and leasing of recreational and sports goods

Croatia Clear clarification of the criteria for classifying renting of boats into classes 77.34 and 77.21, especially regarding yacht charter – what is the borderline, does this size criterion have any relevance in terms of activity classifications? Separate yacht charter into separate class


Croatia New classes: - leasing of pleasure boats and sailboats and other recreational and sports equipment


Croatia New classes: - leasing of pleasure boats and sailboats and other recreational and sports equipment


77.22 - Rental of video tapes and disks

Netherlands Delete classes which are not very relevant like 58.12 Publishing of directories and mailing lists (not many enterprises, content not very clear) and 77.22 Rental of video tapes and disks (outdated and not many enterprises).


77.29 - Rental and leasing of other personal and household goods

France The rental of videocassette and video discs is an activity in the process of extinction (turnover of 16M€). It should be grouped with another class of activities, for example 77.29 (turnover of € 3.8 billion).


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77.40 - Leasing of intellectual property and similar products, except copyrighted works





78 - Employment activities

Italy Babysitters and ‘au-pairs’ agencies to be added Type of change: New code Comment:

Switzerland In Switzerland, it is difficult to distinguish activities of employment placement agencies (7810), temporary employment agency activities (7820) and other human resources provision (7830). No distinction needed between these three codes. We would welcome a grouping of these classes.


78.20 - Temporary employment agency activities

Slovenia We believe that more clear explanations are needed for the classes: NACE 78.20 Temporary employment agency activities and 78.30 Other human resources provision.


78.30 - Other human resources provision

Slovenia We believe that more clear explanations are needed for the classes: NACE 78.20 Temporary employment agency activities and 78.30 Other human resources provision.


79 - Travel agency, tour operator and other reservation service and related activities

Italy Online sale of coupons to participate in cultural events to be added Organization of underwater excursion with a guide to be added


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79.11 - Travel agency activities

France Travel agencies (79.11) and tour operators (79.12) could merge (respective turnover of 4.6 and 7.3 billion euros): these activities are often hard to distinguish, and 79.11 is declining.


Hungary We suggest to change the name of 79.11 “Travel agency activities” for 79.11 “Travel-related intermediary activities”.

Type of change: Other change Comment: Reasoning: Not only travel agencies do this kind of activity. NACE is an activity classification, so we suggest to use an activity description instead of the names of economic units.

79.12 - Tour operator activities

France Travel agencies (79.11) and tour operators (79.12) could merge (respective turnover of 4.6 and 7.3 billion euros): these activities are often hard to distinguish, and 79.11 is declining.


Hungary We suggest to change the name of 79.12 “Tour operator activities” for 79.12 “Arranging and assembling tours”.


79.90 - Other reservation service and related activities

France Concerning the problems relating to the misidentification of the activities of digital actors, here is a list of classes in which we find easily recognizable companies with a strong cultural dimension (but today systematically ignored in economic or professional studies, in because of their NACE code): Class 47.41 (Retail sale of computers, peripheral units and software in specialised stores) includes retail sale of video game consoles; it might be wise to create a class "Retail sale of electronics games" Class 47.78 (Other retail sale of new goods in specialised stores) includes activities of commercial art galleries, which we would like to be able to isolate Class 47.91 (Retail sale via mail order houses or via Internet) includes the specialized retail trade of products via the Internet, and therefore contains Amazon, whose turnover is related to the sale of cultural products. It would seem wise to refine this class Class 61.30 (Satellite telecommunications activities) includes packages of television channels such as Canalplay Class 62.01 (Computer programming activities) contains companies which nevertheless have a cultural activity: for example Deezer (Odyssey music group), whose main activity is to offer music listening on the Internet, Art2M, whose main activity is the production and distribution of digital art works, or KazoArt, contemporary online art gallery Class 63.11 (Data processing, hosting and related activities) contains some online art gallery, such as Zeuxis Class 70.10 (Activities of head offices) includes Google France, which owns Youtube Class 73.11 (Advertising agencies) includes by misunderstanding some companies such as Spotify, whose main activity is listening to music on the Internet Class 74.90 (Other professional, scientific and technical activities n.e.c.) includes activities performed by agents or agencies on behalf of individuals and usually consisting of obtaining their recruitment in films, theatrical productions, other shows or sports events and to place books, plays, works of art,

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photos, etc. at publishers, producers, etc. Class 79.90 (Other reservation service and related activities) includes reservations for shows, which should be classified as 90.02 (Support activities to performing arts).


Hungary You can read in the explanatory notes of NACE 79.90: “- other travel-related reservation services: - reservations for transportation, hotels, restaurants, car rentals…”. But you can not find any category in CPA 79.90 for above activity. We classify the reservation for transportation and hotels into NACE 79.11, and CPA 79.11 has subcategories for this. For example Booking.com is classified into 79.11 in our the Hungarian BR. Where to classify the reservation for restaurant or car rentals? Proposal: In order to solve above problems, the explanatory notes of NACE 79 should be revised, and CPA 79 should be made conform to NACE 79. For example to create new CPA subcategories for the reservation of restaurants and car rentals in CPA 79.11 or?


80.10 - Private security activities

France The turnover of survey activities (80.30) is very low (€ 65 million) and these activities could be grouped with private security activities (8010, turnover of € 6.9 billion).


80.2 - Security systems service activities

France Security systems service activities (80.2): some companies that are only trading consider themselves to have a security system activity, as is the case for companies that conduct security training, or simply test fire extinguishers


80.30 - Investigation activities

France The turnover of survey activities (80.30) is very low (€ 65 million) and these activities could be grouped with private security activities (8010, turnover of € 6.9 billion).


81.21 - General cleaning of buildings

France Cleaning activities (81.22 vs 81.21): the term "undustrial" is misunderstood by companies that confuse "industrial" with "in an industrial environment".


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81.22 - Other building and industrial cleaning activities

France Cleaning activities (81.22 vs 81.21): the term "undustrial" is misunderstood by companies that confuse "industrial" with "in an industrial environment".


81.29 - Other cleaning activities



82 - Office administrative, office support and other business support activities

Italy Web contact centre to be added Type of change: New code Comment:

82.11 - Combined office administrative service activities

France - 82.11 and 82.19: are 2 activities enough to become a combined activity to be classified in 82.11? personal services and home help: 88.10 and services classified in a specialized way (81.21,81.30,53.20,...)


France The content of the "Combined Administrative Services" item (82.11) contains a wide range of services and needs to be clarified.


Hungary Multinational companies usually outsource the ancillary activities to SSC registered in another country and possessing educated/qualified and cheap labour/personnel. SSC businesses usually carry out ancillary activities e.g. accounting, HR, customer service, marketing, IT development etc. The activity of SSC businesses is heterogeneous so it is difficult to choose the right NACE code for principal activity. For example: accounting: 69.20.23, HR: 70.22.14; programming: 62.03.11; website design: 63.11.12; catalogue, poster: 73.11.11 etc. We have several options to classify SSC into an appropriate NACE code. 70.10 “Activities of head offices” 82.11 “Combined office administrative service activities” We have a dilemma whether the activity of SSC is administrative or professional activity? 70.2 “Management consultancy activities” Where to classify SSC in the present NACE? Some SSCs carry out their activity not for “mother company” within the same multinational company”, but for other companies (outside of multinational company). Where do you classify this SSC?

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Proposal: to make more precise the explanatory notes of NACE 82.11, 70.10.


82.19 - Photocopying, document preparation and other specialised office support activities

France - 82.11 and 82.19: are 2 activities enough to become a combined activity to be classified in 82.11? personal services and home help: 88.10 and services classified in a specialized way (81.21,81.30,53.20,...)


Hungary It is difficult to find a borderline between 18 and 82.19. The explanatory notes of 82.19 say: “The document copying/printing activities included here cover only short-run type printing activities” Is this the principal? Or only “office support activities” are included in 82.19? Copy General company is classified into 82.19 in the Hungarian BR. We have doubts about it. We would classify Copy General into 18, according to its activity.


82.20 - Activities of call centres

Hungary It is necessary to extend this activity class for the same services provided via Internet. Type of change: Other change Comment:

Sweden Clarity in the delimitation of activities based on digital platforms are required in a revised NACE. For instance the case of Uber who provides intermediation of car rides. Sweden would like to consider this type of activity under activities of call centres (NACE Rev. 2 (82.20)), instead of under Computer programming, consultancy and related activities (NACE Rev. 2 (62)).


82.92 - Packaging activities

France The packaging services (82.92) seem rather to correspond to an industrial service. The question of their reclassification arises.


82.99 - Other business support service activities n.e.c.

Austria The sale of bitcoins should be mentioned in the explanatory notes in 82.99. Type of change: Complete explanatory notes Comment:


Type of change: Split

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Comment:

France There are still many companies in this class that provide intergroup IT, administrative or central purchasing services. The list of excluded borderline cases should be longer and more explicit to avoid the presence of too many companies that should be classified elsewhere.




Lithuania Too broad range of services already. Type of change: Split Comment: Separate Intermediaries in services and all services related to the virtual currency

O - PUBLIC ADMINISTRATION AND DEFENCE; COMPULSORY SOCIAL SECURITY

Switzerland Here, it would be interesting to point out that these activities can be carried out by both public administrators and private companies. The change of the title and clearer explanatory notes would make sense.


84 - Public administration and defence; compulsory social security

Netherlands The criteria for classifying a category of activities into the division 84 should be made more explicitly. Activities which by definition can only be done by authorities should be part of 84, that is clear. But how is decided where a category of activities which can be done by both private enterprises and authorities will be placed, for instance fire prevention, collection of waste. For instance, following which criteria are private prisons classified in group 84.2 and police laboratories not. The title of 84.2 doesn’t give any direction: “Provision of services to the community as a whole”, that entails a big part of NACE (education, health care….). Also the criteria to classify some Ministries into 84.1 and some into 84.2 should be clarified


84.11 - General public administration activities

France The activity of peri- or out-of-school childcare for school-age children is not isolated in a dedicated sector as it is the case for pupils (88.91 Child day-care activities). The actors of this sector are thus dispersed in several divisions and classes, notably 84.11 General public administration activities (many childcare services being organized by local authorities) or 94.99 (Activities of other membership organisations n.e.c.) The activity of peri- or out-of-school childcare for school-age children is not isolated in a dedicated sector as it is the case for pupils (88.91 Child day-care activities). The actors of this sector are thus dispersed in several divisions and classes, notably 84.11 General public administration activities (many childcare services being organized by local authorities) or 94.99 (Activities of other membership

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organisations n.e.c.)


84.23 - Justice and judicial activities

Denmark Class 84.23 could possibly be split into 2. Type of change: Split Comment:

P - EDUCATION

Slovenia In NACE Rev. 2 are for structuring categories on section P- Education used references to the content of the International Standard Classification of Education (ISCED), the categories of the previous version - i.e. ISCED 1997. This classification was revised, the new version is ISCED 2011. The ISCED 2011 classification has two classification schemes (for programs, for qualifications) and is substantially more classified at the first classification level.


85 - Education

Estonia Please add to the division a new group “Cultural non-formal education” Please add to the new group new classes: 85.71 Dance non-formal education; 85.72 Music and art non- formal education; 85.73 Other non-formal cultural education. Proposal makes cultural economic activities extractible on 3 digit level of NACE according to ESSNet Culture final report and UNESCO FCS 2009.


Italy Activities of educators of environmental projects, conscious consumption, nutrition, reading promotion, creative ateliers, etc. to be added. In general, schools contact such educators to provide ad hoc lessons


85.51 - Sports and recreation education

France It should be interesting, where possible, to better isolate specifically sporting activities. For example, class 85.51 (Sports and recreation education) seems to juxtapose heterogeneous activities. The teaching of card games or yoga in particular could be distinguished from the rest of the activities, thus isolating the teaching of sports activities. At first glance, there could also be a redistribution of activities between 93.21 (Activities of amusement parks and theme parks) and 93.29 (Other amusement and recreation activities) in order to make them more homogeneous and better isolate what is entertainment, for example within subclass 93.21, which would become "Amusement parks, theme parks and other entertainment activities".


Slovenia The organization of the Yoga Federation of Slovenia disagrees with the classification of yoga under sport, class NACE 85.51 Sports and recreation education, because yoga rejects the sporting approach

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and includes much more than just teaching asana - body positions. They believe that yoga is not a gym, recreation or sports activity. They want to consider the possibility of classifying the yoga or traditional yoga in class NACE 85.52 Cultural education.


85.52 - Cultural education

Slovenia The organization of the Yoga Federation of Slovenia disagrees with the classification of yoga under sport, class NACE 85.51 Sports and recreation education, because yoga rejects the sporting approach and includes much more than just teaching asana - body positions. They believe that yoga is not a gym, recreation or sports activity. They want to consider the possibility of classifying the yoga or traditional yoga in class NACE 85.52 Cultural education.


85.59 - Other education n.e.c.

Slovenia We propose establishing of a new class for language teaching (instruction and conversational skills instruction - now NACE 85.59 Other education n.e.c. ) Language teaching is an important part of education in terms of content and amount. We are detecting many programs and participants, particularly in non-formal education. The situation is similar as regards “computer courses”. We think that the content of the existing subclass 85.59 is diverse and that the future revision should perhaps include establishing a special subclass for “language teaching”. It would also be appropriate to think about the situation regarding the content of “computer courses”.


Q - HUMAN HEALTH AND SOCIAL WORK ACTIVITIES

France To identify and specify the categories relating to home helpers or social housing. Indeed, the diversification of these activities certainly calls for changes or clarifications of definition. Certain activities are probably at the crossroads of two categories: some home help services which have both a service activity and a support activity, which fall into two different categories, or even foster care which could end up in "Social housing for children in difficulty" as well as in "childcare for young children".


Netherlands The split into three divisions is changed into two divisions: o 86 Health care and long-term care o 87 Social work, sheltering and youth care


Netherlands A proposed new structure is based on the way health and long-term care and social work are organized nowadays. Residential and non-residential care are more and more combined within the same unit. Hospitals combine the treatment of inpatients with treatment of outpatients. Nursing and other personal care are often given at home done by units which also offer residential care (= care in accommodations of the unit).

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Netherlands Alternative structure and titles: 86 Health care and long-term care 86.1 Specialized medical care 86.11 Hospitals 86.19 Other specialized medical care (no psychiatry) 86.2 General medical practices, dental practices and paramedical practitioners 86.21 General medical practices 86.22 Dental practices 86.23 Practices of midwives 86.24 Practices of physiotherapists 86.25 Health centres 86.29 Other paramedical practitioners (no psychotherapists and psychologists) and alternative healers 86.3 Pharmacies 86.30 Pharmacies 86.4 Preventive health care and ancillary activities for health care 86.41 Preventive health care 86.42 Medical and diagnostic laboratories, intensive care for thrombotic patients and other analyses supporting medical treatment 86.43 Ambulance and patient transport and related emergency centers 86.49 Umbrella organizations in the field of health care and other ancillary activities for health care 86.5 Mental health care and substance abuse care 86.50 Mental health care and substance abuse care 86.6 Care for the disabled 86.60 Care for the disabled 86.7 Nursing, care and assistance of chronically ill and elderly (no mental health care and care for the disabled) 86.70 Nursing, care and assistance of chronically ill and elderly (no mental health care and care for the disabled) 87 Social work, sheltering and youth care 87.1 Social work 87.10 Social work 87.2 Sheltering 87.21 Child day-care 87.29 Other sheltering 87.3 Child care, child protective services and child probation 87.30 Child care, child protective services and child probation

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Spain The increase of the age in the population creates the need for new activities relating the care of the elderly and caring for the mind and body. In the classification, in the area of social services, it is tried to establish groups according to medical care and the different population groups, but it is confusing, mixing the criteria. In the area of health, increasingly they are taking more importance, following the initial reasoning of this section, the sanitary activities not exercised by doctors. These activities are all included in the same code.


86 - Human health activities

Italy Holistic treatments to be added Type of change: New code Comment:

Netherlands The split of Specialized medical care into care with and without accommodation is of decreasing importance: in practice hospitals and outpatient treatment are often combined. So it is proposed to combine the activities of 86.10 Hospital activities and 86.21 General medical practice activities into a new group: 86.1 (new) Specialized medical care


Netherlands The same reasoning can be applied to mental health care (in 86.5 Mental health care and substance abuse care practices and residential care are combined) and also to 86.6 Care for the disabled and 86.7 Care for chronically ill and elderly, where residential and home care are classified because these activities are often combined.


Netherlands Pharmacists “are healthcare professionals, focusing on safe and effective medication use” (Wikipedia). Therefor the activity of a pharmacy should be considered as a part of health care. Moreover, Pharmacies are considered health care in the System of Health Accounts.


Portugal Create a new class/group 8630 – Non-conventional therapies activities We have a resolution of our Assembly of the Republic to create a Class to those activities. The non-conventional therapies includes: homeopathy, acupuncture, phototherapy, traditional Chinese medicine, naturopathy, osteopathy, chiropraxis


Switzerland For General medical practice activities (8621), according to the evolution of the practice of healthcare, it would be useful to replace “general medical practice activities” by “primary care” and to extend the scope of this activity to the definition of WHO about primary health care.

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For Specialist medical practice activities (8622), according to the evolution of the practice of healthcare, it would be useful to define it as the medicine that is not practiced by primary care practitioners. For medical activities (862), there is an additional category missing. It tends to become widespread that the activity can be both primary care / general medical practice activities (8621) and specialist medical care (8622), for example in ambulatory policlinics lead by doctors. It would be necessary to create a new class (for example 8624).


86.9 - Other human health activities

Lithuania Untraditional medicine considered in this class. These activities should be separated from traditional medicine. In Lithuania we are going to regulate this sector so it would be good to consider this activity important to separate and have comparable statistics between countries.


86.90 - Other human health activities

Croatia Further breakdown of activities – it could be useful to separate activities of paramedical practitioners: - Activities of paramedical practitioners (includes nurses, midwives, physiotherapist, psychotherapist, other paramedical practitioners, alternative healers) - Other human health activities (includes activities of medical laboratories, blood banks, sperm banks, ambulance transport etc.)


France Strong demand of criteria to distinguish these activities in the notes of the nomenclature : e.g. activities of magnetizers, of healers, hypnotherapist or psychologist with therapeutic vocation. Note: what to do with wellness activities provided within the firm? (sometimes related to janitorial services)




87 - Residential care activities

Lithuania The Social Services Law and the Civil Code of Lithuania establishes a new form of guardianship (care) for children who have lost their parental care - in the care centre. The Law on Social Services stipulates that the care centre transfers a child who has lost parental care or a child who is facing a social risk to a caregiver guard. A regular caregiver is a natural person who cares for children, having a contract of cooperation and service with a care centre and acting on an individual certificate. For this reason, it is important that there is a clear system for issuing an individual certificate for the caretakers in charge

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of the NACE code.


Lithuania We suggest that the definition of division 87 should be clarified, as the current grouping includes residential care activities that have higher health care services than social services. In groups 87.2, 87.3 and 87.9 do not dominate health care activities. We propose to fundamentally change the division grouping: 87.1 Residential nursing care institutions/activity. (dominant health care activities and less social and care) 87.2. Inpatient/residential care activities (persons with mental disabilities and / or mental disorders, residential care for elderly people and persons with disabilities, where health care services are not dominant). 87.3 Other accommodation-related care activities (social assistance provided to people with mental disabilities and / or mental disorders, children and other categories of people who are partially unable to take care of themselves and / or who have social and personal problems, such as a family home and / a home for independent living, survivors without parental care, temporary residents of homeless people, individuals and families in crisis situations, etc.).


87.2 - Residential care activities for mental retardation, mental health and substance abuse

Denmark We suggest that 87.2 include 87.3 as most (Danish) enterprises don’t distinguish between the types of clients, apart from addicts. The main activity can vary from month to month or year to year.


87.3 - Residential care activities for the elderly and disabled

Denmark We suggest that 87.2 include 87.3 as most (Danish) enterprises don’t distinguish between the types of clients, apart from addicts. The main activity can vary from month to month or year to year.


88 - Social work activities without accommodation

Italy Philosophical counselling activities to be added Type of change: New code Comment:

88.91 - Child day-care activities

Denmark Possibly split class 88.91 into age related day-care activities. E.g. a split between pre-school day-care and day-care activities before and after school hours (we have youth centres and clubs, for leisure activities under supervision by educated staff). We have subdivided the


France The activity of peri- or out-of-school childcare for school-age children is not isolated in a dedicated

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sector as it is the case for pupils (88.91 Child day-care activities). The actors of this sector are thus dispersed in several divisions and classes, notably 84.11 General public administration activities (many childcare services being organized by local authorities) or 94.99 (Activities of other membership organisations n.e.c.) The activity of peri- or out-of-school childcare for school-age children is not isolated in a dedicated sector as it is the case for pupils (88.91 Child day-care activities). The actors of this sector are thus dispersed in several divisions and classes, notably 84.11 General public administration activities (many childcare services being organized by local authorities) or 94.99 (Activities of other membership organisations n.e.c.)


R - ARTS, ENTERTAINMENT AND RECREATION

Austria In the area of culture there are many new activities like culture management or culture intermediary.


90.01 - Performing arts

France Speakers do not always recognize their activity in the wording of Class 90.01 (Performing arts). Type of change: Other change Comment:

90.03 - Artistic creation

France - Artistic creation (90.03): artists in general wish to be classified in 90.03 (To top it all off, in some cases, simply having an activity code 90.03 "proves" the artistic nature of their activity! and in some devices, this code is required to benefit from measures reserved for artists). On this subject, these remarks are similar to those made by statisticians from the Ministry of Culture. > suggestion: class 74.20 for example, specify in the notes that this class includes author-photographers and artist-photographers.


France Class 90.03 (Artistic creation): there is a problem with the wording, which disturbs the legibility of this nomenclature for the cultural professionals and leads therefore to many incorrect classifications (in particular for the independent professionals). Many cultural professionals consider doing "creation", especially photographers, musicians, actors, etc. - even when their activity is to be classified elsewhere. This class "artistic creation" should gather exclusively activities in the visual arts, writing (writers or journalists) and composition. Rephrasing the wording in the sense of its clarification would be a substantial improvement. From this point of view, the clarification is to be provided up to the heading of division 90 (Creative, arts and entertainment activities), which suggests that cultural activities classified elsewhere (photography, audio-visual, book, etc.). are neither creative nor artistic.


91 - Libraries, archives, museums and other cultural activities

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Estonia Please add to the division a new group “Botanical and zoological gardens and nature reserves activities” Proposal makes cultural economic activities extractible on 3 digit level of NACE according to ESSNet Culture final report and UNESCO FCS 2009.


91.04 - Botanical and zoological gardens and nature reserves activities

Slovenia Class NACE 91.04 Botanical and zoological gardens and nature reserves activities is used for the area of nature conservation and it is not logical to join it with the area of botanical and zoological gardens, the actual activity and purpose of which mostly do not have any direct connection with nature conservation. The area of nature conservation covers the protection of valuable natural features and the protection of biodiversity, and the latter covers the protection of plant and animal species and their habitats, habitat types, and ecologically important areas. Therefore, class NACE 91.04, in which only the protection of valuable natural features is stated, is too narrow in terms of subject-matter: We propose establishing of a new class for the area of nature conservation that could be divided into: - Protection of valuable natural features and biodiversity, implementation of nature protection measures - Management of protected areas


93 - Sports activities and amusement and recreation activities

France Consideration should be given to the classification of electronic sport or "e-sport", in particular the organisation of events related to electronic sport. Should this activity, which has recently emerged, be combined with shows or sports-related activities?


Germany The borderline between sports and other recreation activities is not very clear as the criterions on which it is based are. Proposal of change: None. The borderline should be reviewed.


Portugal Create a new class 93.22 - Travelling/itinerant amusement parks We have request from our Government to create a class related to the activities of attractions and fun fair services, carousel services and similar itinerant activities. They need to identify who have those itinerant’s activities by code of “economic activity”, because of the specificity of the itinerant activities


93.21 - Activities of amusement parks and theme parks

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93.29 - Other amusement and recreation activities

Croatia “Operations of Marinas” - we propose the separation of marinas into a new class (further clarification in the additional document)




S - OTHER SERVICE ACTIVITIES

France There is a class "Combined facilities support activities" (81.10) in the "Services to buildings and landscape activities" division: why not create a similar class for combined personal services?


94 - Activities of membership organisations

Estonia Please add to the division a new group “Activities of religious organisations” Proposal makes cultural economic activities extractible on 3 digit level of NACE according to ESSNet Culture final report and UNESCO FCS 2009.


94.99 - Activities of other membership organisations n.e.c.

France Class 94.99 is too general: it is often requested by units with whose legal category is "membership organization" (which is insufficient, if not irrelevant for an activity classification). It would be desirable to clarify a little more clearly, in the notes of the nomenclature, the content of this class and the exclusions.


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France The activity of peri- or out-of-school childcare for school-age children is not isolated in a dedicated sector as it is the case for pupils (88.91 Child day-care activities). The actors of this sector are thus dispersed in several divisions and classes, notably 84.11 General public administration activities (many childcare services being organized by local authorities) or 94.99 (Activities of other membership organisations n.e.c.) The activity of peri- or out-of-school childcare for school-age children is not isolated in a dedicated sector as it is the case for pupils (88.91 Child day-care activities). The actors of this sector are thus dispersed in several divisions and classes, notably 84.11 General public administration activities (many childcare services being organized by local authorities) or 94.99 (Activities of other membership organisations n.e.c.)


Netherlands Some fund raising is classified near the aim they are meant for, for instance fund raising for social work is included in 88.99 Other social work activities without accommodation n.e.c. Other funds raising is part of 94.99 Activities of other membership organisations n.e.c., for instance fund raising for health care. Proposal: combine all fund raising in 94.99.


95 - Repair of computers and personal and household goods

France In division 95, with the exception of computer repair (95.11), sales are rather weak. Clusters could be considered, in particular in the repair of personal and household goods (group 95.2), while keeping the details of the products.


96 - Other personal service activities

Germany Especially due to demographic reasons and economic changes there is an increasing importance of household service activities like cleaning, cooking, laundering, child care etc., offered as a broad set or bundle of support activities. Proposal of change: Creating a new class for non-specialised household service activities.


Italy Services agency (with call centres) to “call” plumbers, electricians, upholsterers, bricklayers and so on, to be added


96.04 - Physical well-being activities



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96.09 - Other personal service activities n.e.c.





99 - Activities of extraterritorial organisations and bodies

Denmark Split into two – one for Embassies/Consulates and one for the rest. Type of change: Split Comment:

Finland Large and complex projects abroad that typically include management, design, installation, erection of complete plants or massive systems for large production units eg. paper mills


99.99 - FREE PROPOSAL

Austria The intermediary of activities is increasing and therefore it should be mentioned more often. Type of change: Other change Comment:

Austria The classification of activities of consultants should be extended: consulting activities should be mentioned in more areas than it is currently the case, for instance in health. Presently almost all consultants are classified in 74.90. This should be changed.


Croatia Generally, an update of the explanatory notes should be carried out and supplemented with the examples of additional and new activities that have emerged on the market in the last few years, at the level of the whole classification.


Czech Additionally we would like to mention a problematic area of outsourcing and Factoryless Goods Producers (FGPs). This is identified in the CZSO as a common issue. However, there is not any unanimous and unambiguous stance on how to proceed. We recommend considering the appropriateness of integrating the activities of these units directly into the classification, i.e. the creation of separate groups/classes for the units which outsource their production. Probably FGPs should be classified separately from the production and the trade.

Type of change: Other change

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Comment:

Denmark FGP: We need a decision about how to treat these before we revise/update NACE! Type of change: Other change Comment:

Finland Subcontracting via a complex setup of contractual agreements where the ownership of inputs is difficult to detect


Finland Activities not covered: invoicing service (an example of such activity https://www.eezy.fi/en/) The class 69.20 Accounting, bookkeeping and auditing activities; tax consultancy becomes close but is not quite covering the invoicing service.


Finland Internet of things - how should services based on this current driver of digital transformation be treated?


Finland Cloud services - the role of cloud providers is growing and the market share of conventional IT-houses decreasing, yet how to classify these service activities? Cloud services are often identified as 1) Infrastructure as a Service (IaaS), 2) Platform as a Service (PaaS), or 3) Software as a Service (SaaS).


Finland Factoryless goods production - should it be classified as manufacturing or service? Type of change: Restructuring Comment:

Finland How to prepare for the fact that the revised classification of economic activities risks to become obsolete very quickly? How to construct a classification that could withstand fast-occurring changes in structures of economies better than the current one? The trend is that companies are constantly looking for new businesses where to excel (digital transformation).


Finland The question arises whether a detailed classification of economic activities based on production of specific goods/services is of any interest any more – or even feasible? Could the classification of economic activities be considerably rougher than the current one? What would be the losses and gains?


Finland The information society is another topic that is difficult to analyse due to limitations of the NACE Rev. 2. For example, the classification does not allow for an analysis of the development of electronic versus paper media.

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Finland Digitalisation radically transforms product structure as well as that of economic activities. Current NACE Rev. 2 seems to absorb changes only to a limited extent. For example, IT services are increasingly being produced outside the traditional IT industries. NACE Rev. 2 – or interpretation of it – seems to fail to recognize new IT services, and as a consequence statistics depict a decrease in the production of IT services in our economy. This has caused strong criticism against the economic classification.


Finland Instead of specific industries, users are rather interested in broader entities, such as the “ICT cluster”, which includes goods production based on information and communication technologies (ICT), telecommunications, service and content production. These activities are characterized by integration, networking and creating new operating models that go beyond the boundaries of the NACE Rev. 2 activity divisions. The borderline between products and services becomes blurred and this leads to further classification problems. For example, should e-commerce that is heavily based on the information technology be part of the ICT cluster or rather sales activities? What about Amazon.com, which sees itself as a technology house, whose core competence is integrating different partners into a service platform that is produced by the company?


Finland Emerging industries/service activities? • Nursing-care robots • Social media activities, eg. youtube stars activities • Collaborative economy / sharing economy


Finland Life cycle solutions as total services to businesses covering design, installation, functioning, maintenance and repairing throughout the lifetime of a product.


France The boundaries between installation/repair/maintenance/industrial activity must be clearly defined, taking into account the problems of data collection (spare parts, maintenance contracts)


France How to classify second-hand mobile phone shops, where a significant part of the turnover comes from the sale of services (repacking and repair).


France In certain activities, in particular electronics, the criterion of possession of raw materials (components) may seem too limited to characterise principals outsourcing the manufacturing production process, given the importance of intangible inputs (software, R&D).


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France The nomenclature misclassifies certain activities today (in particular cultural, but not only) by being blinded by their numerical or cyber dimension, without really describing their object: for example, Deezer (listening to music on Internet ), Art2M (production and dissemination of digital art works) and KazoArt (online contemporary art gallery) are classified 62.01 (Computer programming activities), Amazon is in 47.91 (Retail sale via mail order houses or via Internet), ... Given the importance taken by some of these digital players and their increasing number, it becomes more and more problematic to find them aggregated in classes that describe their activity less than the tools used in the context of activity that remains indefinitely.


France The electronic cigarette: it is a pity not to be able to isolate this product in order to see if the drop in the production of conventional cigarettes mirrors an increase in the production of electronic cigarettes.


France The activities of manufacturing, installation and sale of connected objects: what rules and criteria to know if we classify according to the product (fridge) or if we classify the connected part of the product (watch, pillow)? > connected watch (mail, alerts, physical tracking ...) > connected pillow (security alert, remote control tv / heating / shutters) > connected fridge (shopping list, internet shopping order ...)


France In the cleaning business, the combined activities weigh very little, while they are put forward by all major groups. This is because this activity is organized most often by collaboration of several legal units within the same group. The enterprise approach could make the combined activities bigger and give them an interest whereas they do not seem to have it today.


France Manufacture of signage equipment: some companies manufacture signs in all materials (plastic, metal, luminous,...): it is impossible to keep a code of activity stable from one year to the next. More generally, in classifying manufacturing activities, should we give priority to the type of good produced or the material that constitutes it?


France Differentiate between consultants and experts: with the development of business start-ups in areas of advice or expertise, it becomes difficult to classify new activities and to distinguish between consulting and expertise: > consultants in career path (example in culinary path) > event planning consultants


France Animation activities vs. teaching activities > facilitation of tutorials for students > sport instructor/entertainer > entertainment in retirement homes

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France High tech activities It would be necessary to develop a more up-to-date, accurate and relevant codification for all aspects of new technology and information technology activities (such as digital coaching), environmental activities and personal assistance activities.


France A certain number of activities carried out by "false independent" micro-entrepreneurs are difficult to classify, for example: writer/reader/proof-reader, forklift operator, "support staff", …


France Activities related to new computer ITs: strong demand to better describe these activities in the notes of the nomenclature, in particular concerning maintenance contracts related to repairs and other services. In addition, self-employed micro-entrepreneurs often declare a profession rather than an activity: > virtual community animator > community manager > web manager > internet evaluator > blogger > streamers > youtubers


France Booking platforms: many platforms are created for booking services (eg booking taxis, beauty treatments, hairdressers, ...). How to classify their activities? We know through CPA notes (49.32.11) that the reservation services connected to taxi services are to be classified in 49.32. Is the same rule to be applied in other sectors of activity?


France Activities related to events: > the organisation of events > provision of services related to the organisation of an event: rental of equipment, hire of equipment with operator, provision of hostesses, promotion of the event....


France There are classes corresponding to combined activities. Strong demand to better describe the classification criteria for these combined activities.


France Identification of personal services: Three classes largely cover personal services: activities of households employing domestic services (97.00), home help (88.10) and care for young children (88.91). However, the field thus defined is both too broad and too narrow: it includes activities carried out outside the home (such as childcare in crèche and day-care centres), while many organizations are not counted because they are classified

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according to their activities, for example education (85.51, 85.52, 85.59), tutoring (85.59), or home computer support (62.09). It is therefore difficult to identify undertakings producing personal services from the usual sources and the NACE classification.


France The NACE should be better articulated with the classifications of actors (professional branches); or at least the NACE should be better taken into account by the actors (companies, branches, etc.)


France Poor identification of the tourism sector, the social and solidarity economy, and the digital economy. The nomenclature does not allow reasoning by chain.

Type of change: Restructuring Comment: France The use of turnover or payroll as a proxy for value added is difficult in some sectors: - In the public sector: some public administrations or public institutions behave like companies, so the workforce can be used. But it is not always the case. - Activities of other membership organisations: what should be taken into account: turnover? workforce? Or the corporate object the organisation? > e.g. a neighbourhood football club has no employees but only volunteers (payroll = 0), and its turnover is limited to the sale of drinks from football matches (56.10 or 47.8). Does this unit have to be classified for the most important economic revenue (beverage sales) or for its football club activity (93.1)? - Performing arts companies: how should funding be taken into account? Often the organization of shows is only done thanks to funding: if they are ignored, the company will be classified according to its turnover, in class 90.04. - The vine grower who makes his wine is classified in 01.21; the same goes for the olive grower who makes olive oil and for the goat farmer who makes goat cheese: is this list exhaustive or can it be extended? Ex: fruit tree grower who produces fruit juice?


France Stabilization: - How to manage with the activity code of companies that change their activities every year because their branches of activity vary every year? > e.g. a building company: electricity, painting, masonry... - How to manage with the activity code of companies with cyclical activity? > e.g. a film production company, which then broadcasts and markets films in subsequent years. - How to manage with main activity classification when the base material changes every year? > e.g. manufacture of ceramic, plastic and porcelain dishes....


France The new "false self-employed" entrepreneurs: More and more individuals are starting a business as self-employed persons at the request of their "employers". Thus, many jobs corresponding to in-house services are created and have to be classified according to NACE. Some services are clearly described in the nomenclature (e.g. secretary, housekeeper), but others are not, and their classification becomes difficult. > in the field of catering: servers, divers, butler > in service companies: medical analysis laboratory technician, call centre employee (e.g. computer hotline or pink messaging), health centre coordinator, proof-reader...

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> in the retail trade: supermarket salesman, petrol station pump operator, management of independent home sales teams...


Hungary To review the services connected with internet and classifying them into appropriate class depending on whether Internet is a technical condition (tool, surface) assisting service or not. The explanatory notes should be made clearer how to select the right NACE class (border lines).


Hungary Proposal: to make clear the content of n.e.c classes, to list more concrete examples in the explanatory notes especially in the fields of services e.g. 74.90, 82.99.

Type of change: Other change Comment: Ireland We have a problem with cases such as social media and search engines and platforms. We understand that these types of companies generate their revenue from advertising. However we classify them in the IT sector. In BOP in fact we classify their output as computer services. This leads to asymmetries when other countries classify costs as advertising.


Ireland One of the gaps identified in the context of the digital economy is the classification of platforms such as Uber and Airbnb that don't have any cars and don't have any hotels. This is a very definite gap and may need a new activity code such as 'matching activities'.


Italy Industry 4.0 related issues have to be taken into consideration. Type of change: Other change Comment:

Lithuania Many different sectors of activity are listed in EC Regulation No. 251/2009, however, a frequent user searching for definitions (targeted activities) in the classification of activities itself: - Advanced Technology; - Medium progress; - IT sector

Type of change: Other change Comment: Along with the names of the activities, their explanations and comments, in the classification, the sectoral definitions (inclusive activities) should be provided

Lithuania Could be separate class for a personal transporter (also personal light electric vehicle, personal mobility device, electric rideable ) is a class of compact, portable, electrically powered electric vehicle for transporting an individual at speeds that don't normally exceed 25 kilometres per hour (16 mph), which includes electric skateboards, electric kick scooters, self-balancing unicycles and Segway’s. Other category could include electric bicycles (that are considered to be a type of bicycle), electric motorbikes and scooters (that are treated as a type of scooter (motorcycle) and powered mobility aids

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with 3 or 4 wheels on which the rider sits (powered mobility scooters).

Type of change: New code Comment: Bicycle have their separate class, motorcycles also, this new modern vehicles should have their separate class or vehicle grouping should be revised.

Lithuania Business gifts (Companies purchases very diverse goods and products, logos drawings etc. they can be printed, engraved, embroidered, etc., then sold, to the companies as a business gifts) Could be just guidelines how to interpret and classify such activity

Type of change: Complete explanatory notes Comment: Lithuania Advanced technology industry (high-tech): 3D printing; laser production; robotics; biotechnology; nanotechnology; etc. Separate classes for these activities, not differentiated by products or main raw material but by the technology, technics. Single definition required for the common understanding.

Type of change: New code Comment: In this industry some activities like 3D printing or laser production have no specialization by the products, the technology allows manufacture different products from different materials; difficult to classify, generates huge income; this is developing economic area that not well reflected in NACE and in the Official statistics. Because the high-tech sector of the economy develops or uses the most advanced technology known, it is often seen as having the most potential for future growth. OECD has two different approaches: sector and product (industry). The sector approach classifies industries according their technology intensity, product approach according to finished products: • Aerospace • Audio Technology • Automotive • Artificial Intelligence • Automation • Biotechnology • Bioinformatics • Computer Engineering • Electrical and Electronic Engineering • Information Technology • Medical devices • Nanotechnology • Nuclear Physics • Photonics • Robotics • Semiconductors • Telecommunications • Electromagnetic Engineering Further analysis from OECD shows that using research intensity as an industry classification indicator is also possible: Biotechnology and Pharmaceuticals; Aircraft & spacecraft; Medical, precision & optical instruments; Radio, television & communication equipment; Office, accounting & computing machinery; Electrical machinery & apparatus; Motor vehicles, trailers & semi-trailers; Railroad &

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transport equipment; Chemical & chemical products; Machinery & equipment. e.g. (biotechnology): We do not currently have the relevant statistical information on the state and development of biotechnology and such statistics would allow public authorities, academia and business to obtain a comprehensive economic and individual statistical picture needed for policy making, implementation and business development planning. http://www.oecd.org/science/biotech/keybiotechnologyindicators.htm Often, users are requesting statistics for new groups of activities, but there is no general agreement what these activity groups / sectors are specifically included. Malta Retail trade/Installation of solar water heaters is one of the activities that increased its popularity. This activity needs to be clearly specified.


Malta More details about financial activities, software, communication, and business services activities are required. These can be included in an updated Manual.


Netherlands The production of a good consists of buying input/process/selling output and is triggered by entrepreneurship: the initiative and risk to produce something. The process should change the input into an other product as output. In terms of impact on the economy (employees, investments) and value added the process of making goods is the most characteristic and important part of manufacturing. This is a reason to separate producers of goods with this process from producers which outsource this process. NL proposes to create a separate category for all factoryless producers. Also factoryless producers which don’t own the input should be classified into this new category. In practice the criterion of owning the input can be arbitrary and artificial. Factoryless producers have more in common with each other than with producers with a factory producing the same good.


Poland It is needed to solve the classification problem of Factoryless Goods Producers (FGPs) because at present stage there is no cohesion in classifying the activity of these units. The treatment of the FGPs outsourcing the whole production process is different. Some FGPs classify their activity to the manufacturing sector, another to the wholesale trade. We suggest to separate the distinct grouping(s) for this kind of activity.

Type of change: Other change Comment: Slovenia In general, individual branches of industry should be reviewed and codes should be adjusted to new production processes. Where should we classify automation and robotisation of the production process?


Slovenia We consider that it would be necessary for the following activities to be explicitly stated in the NACE classes: • Emission rights trading activities • 3D modelling • Factoryless goods producers (FGP) • Private fire brigades - NACE 84.25 Fire service activities

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• Drywall installation (construction)


Spain More and more Organisms are emerging, whose classification is not clear if it belongs to Public Administrations. Although there is a criterion that if the activity carried out by the Agency exists in the Classification, it will be coded in this activity, for example education. It is not always obvious, because it could be activities of the public administration, which are beginning to carry out private entities. These activities have an important weight in the economy and whose information would be lost.


Spain Society demands new forms of leisure, such as cultural tourism or creative tourism, associated with new technologies. This is giving rise to new activities not properly collected in the classification. For example, virtual reality or sending messages in geo positioning.


Spain Green economy is understood as that which leads to the improvement of human well-being and social equality, while environmental risks and ecological scarcity are significantly reduced. It should take into account activities such as organic farming, organic livestock , clean energy, biofuels, energy from organic waste or renewable energies.


Sweden This is not a direct suggestion, but we think that it would be an idea to scrutinize the relations between Sections, Divisions and Groups. Could it be an idea to have at least two Divisions under each Section? At least to investigate if there is an indifference in the evaluation process, depending on the Section, when deciding how to group Divisions when creating an activities classification.

Type of change: Other change Comment: Sweden Globalization makes it difficult for the business statistics when companies who outsource their production of goods but keeps R&D and management within the own country. In some cases, the business statistics want those companies to be part of manufacturing. Therefore, it would be helpful if it were possible to find a way or a structure in a revised NACE to single out those particular companies on, for instance, a Group-level.


Switzerland More clarity in the explanatory notes would improve the classification of the units. Type of change: Complete explanatory notes Comment:

Switzerland FGP/ outsourcing Where should we classify them? Manufacturing? Trade? Create new classes?

Type of change: New code Comment: United The treatment of the Creative Industries in relation to producing a mutually exclusive set of codes to clearly reflect their activities

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The Creative Industries and UK Digital organisations consider that the limitations of UK SIC 2007 at the NACE Rev 2 & ISIC Rev 4 level (sections and divisions), leads to their activities being undervalued and their contributions to the UK economy being inaccurately measured. Creative Industry Issues: a. NACE Rev 2 is not reviewed regularly enough to reflect an up-to-date view of the economy. Businesses from across the economy, and especially in the Creative Industries are becoming increasingly ‘digital’ in their use of goods and services, yet these activities remain ‘hidden’ within non- digital UK SIC codes, providing an out-dated representation of the economy. b. The highest levels of UK SIC 2007 being those of NACE Rev2/ISIC Rev 4, are inflexible and lack granularity, making it impossible to classify some creative activities within a section relevant to the Creative Industries. c. Lack of flexibility and granularity in the higher levels of NACE Rev2/ISIC Rev 4 impacts on the lower levels of UK SIC 2007, with some groups and classes including activities that are not carried out exclusively by the Creative Industries. This poor identification of some creative activities within UK SIC, has led both to confusion amongst businesses when attempting to self-classify and contributed to the undervaluing and inaccurate measurement of the Creative Industries.


United Inclusion of a code for fibre reinforced plastics such as glass and carbon reinforced plastics. Type of change: New code Comment: There is currently NACE code for companies that produce carbon and glass reinforced plastics. This is a rapidly growing discrete industry (predicted to grow from £2.3bn in 2015 to up to £12bn in the UK by 2030) which provides materials to sectors such as aerospace, defence and automotive. Without such a code, it is extremely hard to understand this market or to effectively manage engagement and support for it.

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