Aviation Industry NAICS and SIC Codes

We frequently get calls from companies that need help identifying the right NAICS code that applies to their business.  We have taken some typical business activities performed by ASA members and captured their NAICS and SIC codes in the table below.

Typically, a NAICS code is assigned based on the primary business activity of the enterprise.  Sometimes, identifying the primary business activity of an enterprise can be difficult if it engages in multiple business activities.  Ideally, the primary business activity is identified by the relative share of capital investment, but in practice, other variables, such as revenue, value of shipments, or employment, are used as proxies to identify the primary business activity.  The Census Bureau generally uses revenue to determine an establishment’s primary business activity.

We have also included the 1987 SIC codes.  Even though the NAICS codes replaced the SIC codes in 1997, some agencies and programs still rely on (or ask for) SIC codes.

Aircraft and Aircraft Parts Business Classification Codes

Business Activity NAICS (2012) SIC (1987)
Aircraft Parts Distribution 423860 5088
Aircraft Sales 441228 5088
Commercial Aircraft Leasing 532411 7359
Repair Station 488190 4581
Aircraft Upholstery Repair 811420 4581
Aircraft Rebuilding 336411 3721
Aircraft Engine Rebuilding 336412 3724
Aircraft Storage at Airports 488119 4581
Engineering Research and Development on Aircraft Parts
on a Contract or Fee Basis (e.g. DER Services)
541712 8731

Aircraft Disassembly

Increasingly, we are seeing members of the ASA community that are disassembling aircraft for parts.  The precise NAICS and SIC for disassembly may vary depending on the business’ primary business activity.  In many cases, it appears that NAICS 488190 (Other Support Activities for Air Transportation) is the best NAICS for aircraft disassembly when the purpose is to recover parts, and NAICS 423930 (Recyclable Material Merchant Wholesalers) is the best NAICS for aircraft disassembly when the purpose is to recover the scrap metal or other materials (this NAICS includes breaking up vehicles for scrap); but NAICS 488119 (Other Airport Operations) may also be appropriate in some cases (especially for a business that focuses on parking of aircraft).

A business that sorts and recycles aircraft materials may also be considered a non-hazardous waste treatment facility under NAICS 562219.

If you need to identify a SIC code for aircraft disassemblers who disassemble on a contract basis to reclaim parts, then it is likely to fall within the scope of SIC 4581, which encompassed both MRO activities and airport operations.  Aircraft recyclers that break up aircraft and sort the materials (without reclaiming parts) would fall within SIC 5093 – but this SIC specifically stated that dismantling for parts was considered to be a distribution activity.  So aircraft disassemblers who disassemble aircraft in order to sell the used parts for their own account would likely fall into SIC 5088 (distribution).

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About Jason Dickstein
Mr. Dickstein is the President of the Washington Aviation Group, a Washington, DC-based aviation law firm. He represents several aviation trade associations, including the Aviation Suppliers Association, the Aircraft Electronics Association, the Aircraft Fleet Recycling Association and the Modification and Replacement Parts Association.

One Response to Aviation Industry NAICS and SIC Codes

  1. I would like to challenge the use of NAICS 488190 for Repair Stations. In a footnote to the 336411/412/413 “manufacturing” codes for aircraft, engines and accessories, respectively, the Small Business Administration states that “concerns performing major rebuilding or overhaul activities do not necessarily have to meet the criteria for being a ‘manufacturer’ although the activities may be classified under a manufacturing NAICS code.”

    Nearly all component MRO solicitations that we see use NAICS 336411 (aircraft/airframe), 336412 (engines) and 336413 (all other components), so we would argue that most Repair Stations should use these codes as their primary NAICS.

    The Small Business standards for these codes are significantly different from 488190, so it could be a big deal for various most repair stations.

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