2010006 Informal Interpretation



Item 5
Sam Sheinberg

Our suggestion is to ask the business people which of the available NAPCS descriptions is closest to the product your client manufactures that relates to the 6-digit code and report the revenues accordingly. You can explain any differences in an endnote. Feel free to contact Census to let them know about this issue.



From: [Redacted]

Sent: Wednesday, October 14, 2020 3:47:39 PM (UTC-05:00) Eastern Time (US & Canada)

To: [Redacted]

Cc: [Redacted]

Subject: NAPCS question

Hi all,

We are advising a client in connection with an HSR, and have run into the situation where none of the NAPCS codes relating to the relevant 6 digit NAICS code seem to be applicable to the client’s products. We looked at the concordance to no avail. The relevant NAICS code is 325194 (although it looks like the 2012 collected product code was 325192). The issue is that the NAPCS codes don’t cover the same breadth of products as the NAICS code. We checked the 10 digit NAICS codes and it turns out that the same issue would have arisen under the old system. We were hoping for your thoughts on how we can resolve this issue.  

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Informal interpretations provide guidance from previous staff interpretations on the applicability of the HSR rules to specific fact situations. You should not rely on them as a substitute for reading the Act and the Rules themselves. These materials do not, and are not intended to, constitute legal advice.

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