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Two companies · two codes

Manufacturer not yet formed

Do not recode Paparazzi Marketing Group as a factory

Paparazzi Marketing Group LLC (2011) files NAICS 541600 — marketing. The ICF manufacturing company has not been named or formed. If counsel later forms a manufacturer, that new entity files manufacturing (candidate 327390) on its first return. SBA Form 1919 says the NAICS on the loan application must match the applicant’s IRS activity code when applicable. Pretending the marketing company was always a manufacturer is how transcripts kill a $5 million ITL.

Paparazzi 2024 / 2025
541600
Management, Scientific, and Technical Consulting Services (marketing) — do not change. Leave it on the filed returns. A formed ICF manufacturer, if counsel later creates one, would use 6-digit 327390 (Other Concrete Product Manufacturing (ICF systems; confirm from actual receipts)) on Form 1919, SAM.gov, and the credit memo — not Paparazzi’s 541600, and not a steel 3323 code as if this were a metal shop.
Do not file
Construction 236115 / 238120 on Paparazzi or on the factory. HUD-code 321991 unless you actually build mobile homes. Steel 332300 as if this were a metal fabricator. Recoding 541600 as manufacturing to chase ITL.

Two filings, if a manufacturer is formed

Paparazzi already filed. The factory has not. SBA size standards and manufacturer programs use the 6-digit Census code on the applicant — which is not Paparazzi unless counsel later decides Paparazzi itself should operate the plant, which this file does not assume.

WhereCode to enterWhat it means
Paparazzi 2024 / 2025 IRS returns541600Marketing. Already filed. Do not recode.
Proposed manufacturer first return327390 / confirm IRS PBA in year of formationICF / other concrete product manufacturing — only after the company exists
Line A / Item 2b–2c on the manufacturer—“Manufacturing insulated-concrete-form (ICF) building systems and factory-built ICF modular housing.”
SBA Form 1919 / lender3273906-digit manufacturing NAICS on the applicant entity, once formed. Attach a one-page crosswalk if the IRS PBA is a roll-up.

Related codes, not substitutes: 327390 Other Concrete Product Manufacturing (candidate primary for ICF systems); 327320 Ready-Mix Concrete Manufacturing (only if ready-mix is the primary receipt — it is not the plan); 332312 Fabricated Structural Metal Manufacturing (rebar cages as a supporting, not primary, activity).

541600 — Management, Scientific, and Technical Consulting Services
Size standard: Receipts-based (Paparazzi’s actual filed code)
This is Paparazzi Marketing Group LLC’s code. Marketing, customer acquisition, sales, contractor management. Leave it on the 2024 and 2025 returns. It is not a manufacturing code and does not qualify Paparazzi for the Made-in-America ITL manufacturer presumption.

Existing company. Not the factory.

Not NAICS 31–33. Not MARC. Not the 90% ITL manufacturer track. Affiliate disclosure only.

327390 — Other Concrete Product Manufacturing
Size standard: Employee-based (confirm current SBA table when filing)
Candidate primary NAICS for a formed ICF manufacturer whose receipts are ICF forms, wall systems, panels and modular concrete assemblies. Confirm from actual production, not from this memo.

ICF systems are concrete products, not fabricated structural steel and not HUD-code mobile homes.

Manufacturing (31–33): ITL 90% if eligible, MARC, 504 manufacturer cap, FY2026 manufacturer fee waivers on qualifying smaller loans.

332312 — Fabricated Structural Metal Manufacturing
Size standard: 500 employees
Supporting NAICS only if rebar cages and fabricated reinforcement are a real, separately identifiable receipt stream. Not the primary story of an ICF plant. Not a way to recode Paparazzi.

Correct for a steel-component shop. Wrong as the primary code for ICF modular housing.

Still manufacturing 31–33 if it is truly the primary activity — which it is not, on this product.

321991 — Manufactured Home (Mobile Home) Manufacturing
Size standard: 1,250 employees
Only for HUD-code manufactured homes (mobile homes) built on a chassis to the Manufactured Home Construction and Safety Standards. Modular homes built to the IRC as adopted by Louisiana and set on a permanent foundation are not this industry.

Mixing this code with IRC modular product is a classification error and a financing error.

Still manufacturing, but it puts the proposed factory in the wrong factory-built housing bucket.

236115 / 238120 — Construction codes (do not file these for the factory or for Paparazzi)
Size standard: Receipts-based, not the manufacturer employee test
236115 is new single-family housing construction. 238120 is structural steel erection. Use construction codes only for a later licensed on-site company, if one is formed. Do not put them on Paparazzi (marketing) or on the factory.

Paparazzi is not a construction company. Recoding it as 23xxxx to look like a builder, or as 31–33 to look like a factory, both fail transcripts.

Construction NAICS is not NAICS 31–33. It is ineligible for MARC, the Made in America ITL manufacturer presumption, manufacturer 504 $5.5 million cap, and the FY2026 manufacturer fee waivers.

Filing rules — marketing company vs proposed factory

Two companies, if a manufacturer is formed — two codes
Paparazzi Marketing Group LLC stays 541600. A formed ICF manufacturer files manufacturing. SBA Form 1919 instructions state: “For purposes of reporting NAICS Code, Applicants must match the business activity code provided on their IRS income tax filings, if applicable.” Recoding Paparazzi’s marketing return as a factory is how the file dies on transcripts.
There is no 2025 factory return
The manufacturing company has not been named or formed. Do not invent a 2025 manufacturer PBA. Do not put 327390 or 332300 on Paparazzi’s 2025 return. The first manufacturing return is the first year a manufacturer actually exists and produces.
Primary activity is a receipts test
The primary code is the activity that produces the largest share of receipts, not the activity you plan to grow into. Paparazzi’s receipts are marketing. A formed factory’s receipts would be ICF systems. Do not file the factory as steel (3323) or HUD-code homes (321991) unless that is actually what it makes.
Do not burn an old LLC to look like two years of manufacturing
Some ITL expansion treatments are smoother when the borrower has operated in the same 6-digit NAICS for at least two years. That is not a reason to recode Paparazzi or to revive a 2013 shell. This factory is a startup. Write it as a startup.
Describe the product in Line A / Item 2b–2c — on the manufacturer, once formed
Something a lender can read: “Manufacturing insulated-concrete-form (ICF) building systems and factory-built ICF modular housing.” Do not write “construction,” “general contractor,” “marketing,” or “real estate development” on the factory return.