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Public Comments

ICR 202611-0607-001 · OMB 0607-0008 · Object 174430200.

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Public Comments
Matthew J Tucker (CENSUS/ESMD FED)
Microsoft® Word for Microsoft 365
2026-09-30
2026-09-30
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August 20, 2026
Thomas J. Smith
U.S. Census Bureau
4600 Silver Hill Rd
Washington, DC 20233
RE:

Federal Register notice of July 20, 2026 for the Census Bureau’s Manufacturers’
Shipments, Inventories, and Orders (M3) Survey (OMB Number: 0607-0008)

Dear Mr. Smith:
The Bureau of Economic Analysis (BEA) strongly supports the continued collection of data by
the U.S. Census Bureau for the Manufacturers’ Shipments, Inventories, and Orders (M3) Survey.
The data collected on these forms are crucial to key components of BEA’s economic statistics.
BEA uses information from the M3 to prepare the national income and product accounts (NIPA),
gross domestic product (GDP) by industry, and the annual input-output (I-O) accounts. BEA’s
quarterly GDP by industry statistics depend upon information from the M3 as well. BEA is
strongly in favor of the proposal to permanently collect and publish advanced total
manufacturing estimates, as well as strongly in favor of the increased detail for the nondurable
goods industries. Attached is a table describing how the M3 data are used currently by BEA.
Please keep BEA informed about any modifications to this form. We are particularly interested
in any modifications proposed during the forms’ approval process that would substantially affect
our use of these data. For additional information, please contact Tiffany Burrell, Source Data
Coordinator, on 301-278-9618 or by e-mail at [email protected]. Should you need
assistance in justifying these forms to the Office of Management and Budget, please do not
hesitate to contact BEA.
Sincerely,

Dennis J. Fixler
Chief Economist
Attachment

ATTACHMENT
Items Used by BEA from the
Manufacturers’ Shipments, Inventories, and Orders (M3) Survey

ITEMS USED
Manufacturers’ Shipments

ESTIMATES PREPARED FOR
NIPAs:
- Quarterly Investment in equipment and
software
-

Monthly estimates of real domestic
inventories, sales, and inventory/sales
ratios

GDP By Industry:
- Quarterly manufacturing output
-

Annual manufacturing output

-

Quarterly gross operating surplus
estimates

I-O Accounts:
- Annual manufacturing output
Manufacturers’ Inventories

NIPAs:
- Quarterly change in private domestic
inventories
-

Monthly estimates of real domestic
inventories, sales, and inventory/sales
ratios

GDP By Industry:
- Annual manufacturing output
I-O Accounts:
- Annual manufacturing output

Page 2 of 2

PUBLIC SUBMISSION

As of: 9/22/26, 1:36 PM
Received: September 18, 2026
Status: Draft
Tracking No. mu7-o4fl-i2ml
Comments Due: September 18, 2026
Submission Type: Web

Docket: USBC-2026-0265
Manufacturers’ Shipments, Inventories and Orders (M3) Survey
Comment On: USBC-2026-0265-0001
Manufacturers' Shipments, Inventories, & Orders (M3) Federal Register Notice
Document: USBC-2026-0265-DRAFT-0003
Comment on FR Doc # 2026-14513

Submitter Information
Name: Andrew Allgood
Address:
NH,
Email: [email protected]

General Comment
Date: 18 September 2026
To: Re: U.S. Census Bureau, Department of Commerce
Proposed extension of the Manufacturers' Shipments, Inventories, and Orders Survey
From: Andrew Allgood
I oppose the proposed extension of the Manufacturers' Shipments, Inventories, and Orders
survey. Collecting this manufacturing data is not a legitimate role of the federal
government.
The notice would continue a monthly Census Bureau survey asking domestic
manufacturers for shipments, new orders, unfilled orders, total inventory, materials and
supplies, work-in-process, and finished goods. That is commercial information about

private firms. The government does not need to compile it in order to perform the few
functions that belong to it. If someone wants this information — a researcher, a trade
association, a bank, a news organization, or a group of manufacturers — they are free to
start an organization that solicits it. Firms that see value in sharing the data can do so.
Firms that do not can decline.
The market already produces industry statistics when buyers will pay for them. There is no
reason for the Department of Commerce to stand in for that process. A government survey
substitutes a tax-funded collection program for voluntary exchange. Even where response
is labeled voluntary, the collection itself is a federal program. That is the point at issue. I do
not believe the United States should operate a monthly factory ledger for the convenience
of data users who could organize and pay for it themselves.
I ask the Census Bureau not to extend this collection, and I ask the Office of Management
and Budget not to approve it. If the data are useful, private parties can gather them.
Respectfully submitted,
Andrew Allgood

Attachments
Allgood_Comment_M3_Manufacturing_Survey

PUBLIC SUBMISSION

As of: 9/22/26, 1:36 PM
Received: September 18, 2026
Status: Draft
Tracking No. mu6-j4ry-zjt3
Comments Due: September 18, 2026
Submission Type: Web

Docket: USBC-2026-0265
Manufacturers’ Shipments, Inventories and Orders (M3) Survey
Comment On: USBC-2026-0265-0001
Manufacturers' Shipments, Inventories, & Orders (M3) Federal Register Notice
Document: USBC-2026-0265-DRAFT-0002
Comment on FR Doc # 2026-14513

Submitter Information
Name: Anonymous Anonymous

General Comment
Assessment of Practical Utility vs. Digital Transition Impact
The notice indicates that paper collection was completely phased out in January 2026 in
favor of internet and email submissions. To help the public and OMB fully evaluate whether
this collection method maintains its practical utility across the entire manufacturing
sector, we request that the Census Bureau clarify:
1. What percentage and total volume of the 5,000 survey respondents were actively using
paper forms immediately prior to the January 2026 phase-out?
2. Has the elimination of paper forms impacted response rates or panel retention among
smaller manufacturing entities that may lack dedicated automated accounting systems?
3. Has the transition to digital-only collection caused any observable shift in non-response
bias across specific 3-digit or 4-digit NAICS industry groups?
We support the Census Bureau’s efforts to modernize data collection and deliver timely
economic indicators. However, providing transparent data on the scale of the paper form
elimination will validate that the digital requirement enhances data utility without
inadvertently excluding non-digital respondents.