On May 22, 2014, the Office of Management and Budget solicited comments on a proposal for changes to the North American Industry Classification System (NAICS) that would take effect in a 2017 revision. The revision would reclassify factoryless goods producers (FGPs) such as Apple and Nike, most of which are now in wholesaling or management of companies, as manufacturers, and move trade by manufacturing service providers (MSPs), such as China’s Foxconn (which builds Apple products) into services. In What is manufacturing and where does it happen?, I show that this proposal would artificially inflate U.S. manufacturing production and employment and deflate U.S goods trade deficits with many countries. It would also irrevocably change U.S. balance of payments accounting. I recommend that OMB should withdraw its NAICS 2017 proposal regarding FGPs and MSPs, and remand the issue to the OMB committee that handles trade statistics policy for reconsideration.

NAICS is used by the myriad federal statistical agencies that collect, analyze, and publish economic data, including data on trade. The OMB proposal was developed to respond to the rapid growth of establishments that design products but outsource most or all of the production process.

The NAICS 2017 proposal—which is part of a broader, international, behind-the-scenes effort to redefine and recalculate U.S. and international trade accounts—would artificially inflate measures of U.S. manufacturing production and employment by arbitrarily moving wholesalers such as Apple and Nike into manufacturing, and changing substantial quantities of the goods we import into services. This would reduce our reported trade deficit in goods (on a balance of payments basis), with no change in our underlying balance of trade. And it would make it appear that U.S. manufacturing output has increased when, in fact, much of the actual manufacturing production has been offshored.

Suppressing measured trade deficits through statistical manipulation is no substitute for better trade and manufacturing policies. Congress should order a comprehensive review and evaluation of recent and planned changes to U.S. international trade and national accounting statistics, and of the international standards on which U.S. trade accounting systems are based.