Use of Wholesale/Retail NAICs for Government Prime & Subcontracts

August 1, 2014

NOTE: The Alaska PTAC has been renamed as Alaska APEX Accelerator. This change occurred on September 15, 2023. Learn why.

SBA had a number of issues and situations recently having to do with improper use of Wholesale NAICs (Sector 42) codes in the subcontracting area.  As you know, Wholesale (Sector 42) and Retail (Sectors 44-45) NAICs are not to be used in connection with Federal prime and subcontracting requirements. There are requirements posted in FBO right now that have the incorrect NAICS codes.  The SBA’s Size Program regulations (Ref. 121.201) clearly state that:

Sector 42—Wholesale Trade

      

(These NAICS codes shall not be used to classify Government acquisitions for supplies. They also shall not be used by Federal Government contractors when subcontracting for the acquisition for supplies. The applicable manufacturing NAICS code shall be used to classify acquisitions for supplies. A Wholesale Trade or Retail Trade business concern submitting an offer or a quote on a supply acquisition is categorized as a nonmanufacturer and deemed small if it has 500 or fewer employees and meets the requirements of 13 CFR 121.406.)

Sector 44-45—Retail Trade

      

(These NAICS codes shall not be used to classify Government acquisitions for supplies. They also shall not be used by Federal Government contractors when subcontracting for the acquisition for supplies. The applicable manufacturing NAICS code shall be used to classify acquisitions for supplies. A Wholesale Trade or Retail Trade business concern submitting an offer or a quote on a supply acquisition is categorized as a nonmanufacturer and deemed small if it has 500 or fewer employees and meets the requirements of 13 CFR 121.406.)