Cookie, Cracker, and Pasta Manufacturing (U.S.) — NAICS 31182

An investor's rollup primer. NAICS = North American Industry Classification System, the federal code system used to define industries. This is the five-digit "industry" level, one step above its two component industries and one step below the broader Bakeries and Tortilla Manufacturing group (NAICS 3118).

1. Overview

NAICS 31182 bundles two neighboring corners of packaged food: the plants that bake shelf-stable cookies and crackers (Oreo, Ritz, Goldfish, Cheez-It, saltines, grahams) and the plants that turn purchased flour into dry pasta, baking mixes, and refrigerated/frozen dough (spaghetti, macaroni, cake and pancake mixes, Pillsbury dough). They share a shelf, a customer (the grocery buyer), and an economic model — buy an agricultural commodity, convert it at scale on automated lines, and sell it for slightly more than the all-in cost. Both are mature, defensive, cash-generative consumer-staple categories where the money is made on input-cost management, capacity utilization, and brand pricing power rather than growth.

Why an investor cares: this is a classic "boring is good" pocket of the food economy. Demand is remarkably steady across the business cycle — people buy cookies and pasta in booms and recessions — but unit growth is low-single-digit at best, so value comes from margins, cash generation, and consolidation. Combined U.S. manufacturer shipments were about $25.7 billion in 2022 [1]. There is no U.S.-listed pure play for either half; public investors get diluted exposure inside diversified food conglomerates, while the concentrated positions sit in private hands — private equity and family ownership on the pasta side, and, after a wave of mega-deals, increasingly private ownership on the cookie/cracker side too.

The distinctive thing about looking at 31182 as a whole is the contrast between its two halves, which Section 2 leads with: they are similar in spirit but differ sharply in size, capital intensity, ownership, key commodity, and the specific regulations and demand shocks that move them.

2. What's inside — the two child industries, and how they differ

NAICS 31182 contains exactly two industries. The core rollup insight: pasta/dough/mixes is the larger revenue half but the smaller employer, while cookies/crackers is the smaller revenue half but the larger employer — meaning the pasta side is markedly more automated and capital-intensive (more dollars per worker), while cookies/crackers is more labor- and marketing-intensive. Their ownership structures, key commodities, and regulatory pressure points also diverge.

(HHI = Herfindahl-Hirschman Index, the standard concentration gauge; below 1,500 is "unconcentrated" under federal merger guidelines. Both children — and the combined level — sit far below that line.)

The practical read: if you want the more discretionary, brand-and-marketing side with higher demand risk (GLP-1 drugs, trade-down to store brands), that is cookies/crackers. If you want the more staple, commodity-conversion side with a durum-wheat cost swing and trade-policy protection, that is pasta/dough/mixes. One public name — General Mills — straddles both, with Annie's crackers/grahams on the 311821 side and Pillsbury dough plus Betty Crocker/Bisquick mixes on the 311824 side.

3. How big it is

Federal ground-truth figures for NAICS 31182 (prefer these):

The rollup reconciles cleanly. The two children sum almost exactly to this level: receipts ($10.29B + $15.39B = $25.68B), establishments (461 + 390 = 851), employees (33,887 + 24,501 = 58,388), and payroll ($1.87B + $1.45B = $3.32B) all tie out [1][2][3][4]. The one small gap is firm count: the children report 386 + 344 = 730 firms, but the level reports 724 — implying roughly six firms operate plants in both industries and are counted once here. That is a feature of the data, not an error, and it hints at the operational overlap (the same corporate parents and co-packers work across biscuits, mixes, and dough).

Concentration is lower at the level than in either child. The level's top-4 firms make 27.4% of shipments, top-8 40.8%, top-20 63.3%, top-50 82.7%, and the HHI is just 332.6 [1] — below both children's HHIs (523.9 and 641.6). This is expected: the leaders in cookies (Mondelez, Mars) are largely different companies from the leaders in pasta (Barilla, Winland), so combining the two dilutes any single firm's share. Read the level as genuinely fragmented at the factory gate, even though each half has a recognizable branded oligopoly at the shelf.

Undercount and scope caveats (read before using the size figures). These are manufacturer numbers — factory-gate output — and they capture the plant base well (this is a capital-intensive industry of large, well-surveyed firms, not tiny informal operators). But $25.7 billion understates the economic footprint of these products for four honest reasons: (a) it is measured before the roughly 2x markup added at retail — the cookies-and-crackers half alone is ~$22 billion measured at retail [5]; (b) closely related output is booked under other codes — supermarket in-store-bakery cookies (311811/311812) and, critically, pasta/mixes/dough made by vertically integrated flour millers (311211 Flour Milling), which pulls a real slice of pasta output out of the 311824 figure [3][4]; and (c) federal manufacturing data count only domestic production, missing the large volumes of imported pasta (Italy) and biscuits (Biscoff, McVitie's) that compete on U.S. shelves — imports from Italy and Turkey covered by antidumping orders alone totaled 552 million pounds in 2023 [17]. Treat $25.7 billion as U.S. factory output, not U.S. consumption.

4. The investable universe — where value concentrates across the two halves

There is no listed U.S. pure play anywhere in 31182. Every public route is a diversified food company for which cookies, crackers, pasta, or mixes is one segment among many; the concentrated exposure is private. Approximate scale figures below are company- or segment-wide, not the NAICS slice alone.

Public companies (all diversified):

Major private / no-longer-listed owners (where the real scale sits):

• Cookies/crackers: Mars (private) became a top cracker owner by acquiring Kellanova for ~$35.9B, closed December 2025 — Cheez-It, Club, Town House [9]. Ferrero (private, Italy) owns Keebler, Famous Amos, and the Girl Scout Cookie baker Little Brownie Bakers, built via a $1.3B purchase of Kellogg's cookie business in 2019 [10]. McKee Foods (family, ~$2B revenue, ~6,600 employees) and a fragmented base of contract/private-label bakers round out the sector [21]. TreeHouse Foods — a major private-label manufacturer — was acquired by Investindustrial in February 2026 and is no longer publicly traded [11].
• Pasta/dough/mixes: Barilla America (Italian family) is the world's #1 pasta maker [7]. Winland Foods (Investindustrial PE) owns American Italian Pasta Company, North America's largest dry-pasta producer and a huge private-label supplier [11][12]. Richardson International (Canadian agribusiness) acquired the 8th Avenue pasta business (Ronzoni) from Post Holdings in December 2025 for ~$375M cash plus ~$80M of assumed liabilities, giving it 278,500 metric tons of combined capacity [22]. The Krusteaz Company (family) and Hometown Food Company (Brynwood PE; Pillsbury shelf-stable baking) round out the mixes side [7][23].

Takeaway: across both halves you accept dilution in the public market — you are buying a big food company for which this is one segment — and you can only reach concentrated exposure (Mars, Ferrero, Barilla, Winland, Richardson, the co-packers) privately. General Mills is the single most efficient public way to touch both children at once.

5. How the money works

Both halves run the same commodity-conversion manufacturing playbook, with the profit levers below. The differences are in which commodity and how capital-intensive.

1. Input cost vs. price is the whole game. Raw materials run roughly 40–50% of cost of goods, and the dominant swing factor differs by half: cocoa, sugar, wheat flour and edible oils for cookies/crackers; durum wheat (semolina) for pasta [8]. Products are cheap per unit and shelf-stable, so the fight is over gross margin — hold or raise price while managing ingredient inflation through hedging, reformulation, and pack-size changes ("shrinkflation"). USDA reported a preliminary U.S. durum farm price of $6.40 per bushel in 2025, down from $9.70 in 2023 — but the July 2026 wheat outlook shows tightening supply [24].
2. Volume and capacity utilization. Lines are automated, continuous, and capital-intensive; profit rises when expensive ovens, extruders, dryers, and packaging lines run full. This is a "pennies per unit, millions of units" model where throughput, not store count, drives unit cost. The pasta side is the more extreme version — hence its ~$628K revenue-per-worker versus ~$304K for cookies/crackers [3][4].
3. Branded pricing power vs. private label. Two profit profiles live under one code. A billion-dollar brand (Oreo, Cheez-It, Goldfish, Barilla, Betty Crocker) earns a premium and guaranteed shelf space; a private-label saltine or store-brand macaroni competes almost purely on cost. Circana data for the 52 weeks ended December 2024 shows Nabisco at $4.4 billion (30% of cookies) and $1.6 billion (15% of crackers) while private label runs $3.1 billion in cookies (21%) and $687 million in crackers (6%) [25]. The same factory skill produces both, but the margin gap is large — branded owners spend heavily on advertising and trade promotion to defend it, while co-packers accept thin margins for steady volume.
4. Distribution scale and product mix. Scale in procurement and distribution is a real moat; some lines use direct-store-delivery to control shelf placement. Within a company, richer-margin categories (refrigerated dough, branded biscuits) versus commodity ones (bulk dry pasta, private-label) drive profitability more than headline revenue.

In short: the branded majors run a high-margin marketing-and-scale model; the private-label/co-pack base runs a low-margin capacity-utilization model. Both are defensive and cash-generative; neither grows fast.

6. What drives demand

• Everyday staples and snacking. Cookies and crackers are inexpensive, storable, impulse-friendly "permissible indulgence"; pasta, mixes, and dough are cheap, filling, at-home cooking staples. Baseline demand tracks population and eating occasions and is very stable across both halves.
• Price and the economy — but in opposite directions. In downturns, cookie/cracker shoppers trade down from brands to private label (shifting who profits), while pasta and mixes are mildly counter-cyclical — demand rises as households cook at home instead of eating out. The pasta half is the more recession-resilient of the two.
• Health and "better-for-you" — cuts both ways. A steady pull toward reduced-sugar, whole-grain, gluten-free, and higher-protein versions is a headwind for classic recipes and a growth lane for reformulated and startup brands (e.g., Banza chickpea pasta, now a top-5 U.S. pasta brand; Simple Mills better-for-you crackers and mixes) [7][19]. Circana/SPINS data identified $224 million of shelf-stable pasta carrying 10–15 grams of protein for the year ended June 2025 [26].
• GLP-1 weight-loss drugs — the new structural risk, concentrated on the cookie side. Glucagon-like peptide-1 medications (Ozempic, Wegovy, Zepbound) suppress appetite; 2025 studies and company commentary pointed to households on these drugs materially cutting snack spending, with cookies and sweet baked goods among the hardest-hit categories [6]. Pasta, a savory dinner staple, is less exposed. This is the first structural demand risk the cookie/cracker half has faced in years.
• Recent volume trends. Growth has been principally nominal. For the 52 weeks ended June 15, 2025, cookie sales increased 0.8% to $11.4 billion while unit sales fell 0.9%; for the 52 weeks ended November 30, 2025, cracker sales slipped 1% to just under $11.1 billion with units down 2.4% [27][28]. Positive dollar sales can mask declining physical volume and operating leverage.
• Seasonality. Lunchboxes and the annual Girl Scout Cookie season anchor cracker/cookie demand; holiday baking drives cake-mix and refrigerated-dough spikes.

7. Regulation

Product regulation is meaningful but manageable, and the two halves face different active pressure points.

• Food safety (both halves). Plants operate under the FDA (U.S. Food and Drug Administration) and the Food Safety Modernization Act (FSMA), which requires written preventive-controls plans. Recalls happen — often for allergen mislabeling (wheat, milk, egg, soy, nuts are core ingredients) or contamination. Sesame became the ninth legally recognized major food allergen effective January 1, 2023 [29].
• Synthetic-dye phase-out (hits the cookie/cracker half hardest). In January 2025 the FDA revoked authorization for FD&C Red No. 3, giving makers until January 15, 2027 to reformulate [14]. Under the broader 2025 "Make America Healthy Again" initiative, HHS (Health and Human Services) and the FDA are pressing industry to voluntarily eliminate the remaining petroleum-based dyes by end of 2026 [15]. This is a real near-term reformulation cost, heaviest for brightly colored cookies, icings, and fillings.
• Trade protection (a structural tailwind for the pasta half). Since 1996 the U.S. has imposed antidumping and countervailing duties (AD/CVD) on certain dry pasta from Italy and Türkiye, most recently continued in September 2024 [16]. In March 2026, Commerce finalized antidumping margins of 2.65% for La Molisana, 7.00% for Garofalo, and 5.21% for non-selected reviewed companies [30]. These duties shield domestic pasta makers from cheaper imports — a durable advantage the cookie side has no equivalent to.
• Commodity and labeling policy (both). The USDA sugar program keeps U.S. sugar prices above world levels (a structural cost for sweet biscuits); flour enrichment/fortification standards, Nutrition Facts (including "added sugars"), allergen declarations, and bioengineered-food disclosure all apply. Possible future front-of-pack labeling is a watch item.

None of this is existential, but the 2026–2027 dye-reformulation deadlines (cookies) and the durability of the pasta AD/CVD orders (pasta) are the two regulatory swing factors to track.

8. Consolidation

Both halves have consolidated heavily and recently, and the common thread is private capital rolling up branded food assets.

• Cookies/crackers — a wave of mega-deals, mostly taking brands private. Ferrero bought Kellogg's cookie business for $1.3B (2019) [10]; J.M. Smucker acquired Hostess (Voortman) for $5.6B (2023) [20]; Mars acquired Kellanova for ~$35.9B, closed December 2025, instantly making Mars a top cracker owner [9]; and Flowers Foods acquired Simple Mills for $795M (February 2025) [19]. Each deal pulled leading brands off the public market or into private hands. TreeHouse Foods was acquired by Investindustrial in February 2026, taking a major private-label manufacturer private [11].
• Pasta/dough/mixes — PE and agribusiness platforms recombining private-label assets. TreeHouse sold its meal-prep business (including AIPC pasta) to Investindustrial for $950M (2022), forming Winland Foods [11][12]; Post's 8th Avenue acquired the Ronzoni brand for ~$95M (2021) and later the rest of 8th Avenue for $880M; then Post sold that 8th Avenue pasta business to Richardson International for ~$375M cash in December 2025 [22]; and in February 2026 Investindustrial agreed to take TreeHouse Foods private for ~$2.9B [11] — the same sponsor recombining private-label food again.
• Two concentration pictures, one theme. At the factory level the level is only moderately concentrated (HHI 332.6) [1] because the co-pack/private-label base is wide. At the brand/shelf level, a short list of owners — Mondelez, Mars, Campbell's, Ferrero on one side; Barilla, Winland, Richardson, General Mills, Conagra on the other — controls what consumers actually reach for. Barriers to entry are high for the branded tier (brand equity, retailer shelf relationships, capital-intensive lines, buying scale) and low for the private-label/co-pack tier, which is why that base stays fragmented and thin-margined. New-brand disruption happens mostly in "better-for-you" niches, which the majors then acquire.

9. Risks

• Input-cost volatility. Cocoa spiked sharply in 2024–2025 (cookies), and a poor durum harvest in Canada, the U.S. Northern Plains, or Italy can spike semolina prices (pasta); USDA's July 2026 wheat outlook shows tightening supply [8][24]. Margins compress when makers can't pass costs through.
• GLP-1 demand erosion. Appetite-suppressing drugs pulling snack volume out of the category over time — the most-watched structural risk, concentrated on the sweet cookie/cracker side [6].
• Volume decline despite dollar growth. Recent data shows unit sales falling even as dollar sales edge up — positive revenue can mask declining physical volume and operating leverage [27][28].
• Reformulation cost and execution. Meeting the Red No. 3 (2027) and broader dye phase-out (2026) deadlines without hurting taste or shelf life [14][15] — a cookie/cracker burden.
• Trade-policy reversal. If the AD/CVD orders on Italian/Turkish pasta were revoked, cheaper imports could take domestic share — a pasta-specific risk [16].
• Private-label trade-down and retailer power. Walmart, Costco, Amazon, and the club channel squeeze pricing and can favor store brands, pressuring branded margins across both halves. Campbell disclosed that its five largest customers represented approximately 47% of consolidated fiscal-2025 sales, with Walmart alone at approximately 21% [18].
• Food-safety recalls. Allergen or contamination recalls carry cost and brand damage.
• Slow top-line growth. Even absent shocks, this is a low-single-digit category; value comes from margins, cash, and consolidation, not expansion [5][7].

10. How to invest, and the outlook

Public routes. No pure play exists at the level or in either child, so public investors buy the parents and accept diluted exposure. The cleanest large-cap reads are Mondelez (MDLZ) for the cookie/cracker half (Nabisco is the largest single U.S. brand collection in that code) and General Mills (GIS) for the pasta/dough/mix half — and GIS uniquely touches both halves (Annie's plus Pillsbury/Bisquick). Campbell's (CPB) adds Goldfish/Pepperidge Farm; Conagra (CAG) adds Duncan Hines mixes; Flowers Foods (FLO) offers growth-oriented exposure through Simple Mills [19]. In every case you are buying a diversified staples company — dividends, defensiveness, modest growth — not a bet on cookies or pasta alone. (Tickers and valuation work belong to individual security analysis, not to this industry view.)

Private routes. This is where concentrated exposure lives, on both halves. Cookies/crackers is now largely held by Mars and Ferrero (both private) plus family and PE-backed co-packers; pasta/dough/mixes sits with Barilla (family), Winland/AIPC (Investindustrial PE), Richardson (agribusiness), Krusteaz (family), and Hometown (Brynwood PE). Private-equity roll-ups of co-packers and private-label bakers, and venture/growth investment in "better-for-you" startups (reduced-sugar and high-protein biscuits; chickpea/lentil and gluten-free pasta) that the majors later acquire, are the main private avenues — and where most of the category's growth now sits.

Near-term drivers to watch:

• Cookie side: whether snack volume stabilizes as inflation eases against the GLP-1 drag [6]; cocoa normalizing [8]; and execution on dye reformulation ahead of the 2026–2027 deadlines [14][15].
• Pasta side: durum-wheat costs through 2025–2026 — recent moderation but tightening supply ahead [24]; continued AD/CVD protection keeping imports in check [16][30]; and the protein/gluten-free niche as the one genuine growth vector [7][26].
• Both: persistent private-label share gains, and more consolidation as scale in packaged food keeps being rewarded by private capital [9][11][22].

Bottom line: a defensive, cash-rich, slow-growing manufacturing level whose two halves rhyme economically but differ in the details that matter — cookies/crackers is the smaller, more labor- and marketing-intensive, GLP-1-and-cocoa-exposed half going private through mega-deals; pasta/dough/mixes is the larger, more automated, durum-and-trade-policy-driven half long held by PE, agribusiness, and families. Own it publicly through diversified food companies (General Mills bridges both), or reach the concentrated positions only through private and private-equity channels.

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Sources

1. U.S. Census Bureau, 2022 Economic Census — Concentration by Largest Firms, NAICS 31182 (receipts, firm count, CR4/CR8/CR20/CR50, HHI). https://data.census.gov/
2. U.S. Census Bureau, County Business Patterns 2023, NAICS 31182 (establishments, employment, annual and Q1 payroll). https://www.census.gov/programs-surveys/cbp.html
3. U.S. Census Bureau, Economic Census 2022 & County Business Patterns 2023, NAICS 311821 — Cookie and Cracker Manufacturing (child-industry receipts, plants, employment, HHI, definition/exclusions). https://www.census.gov/naics/
4. U.S. Census Bureau, Economic Census 2022 & County Business Patterns 2023, NAICS 311824 — Dry Pasta, Dough, and Flour Mixes Manufacturing from Purchased Flour (child-industry receipts, plants, employment, HHI, definition/exclusions). https://www.census.gov/naics/
5. Statista, Cookies & Crackers — United States, Market Forecast, 2025. https://www.statista.com/outlook/cmo/food/confectionery-snacks/snack-food/cookies-crackers/united-states
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14. U.S. Food and Drug Administration, FDA to Revoke Authorization for Red No. 3 (Jan. 2025; reformulate by Jan. 15, 2027). https://www.fda.gov/food/hfp-constituent-updates/fda-revoke-authorization-use-red-no-3-food-and-ingested-drugs
15. U.S. Department of Health and Human Services / FDA, HHS, FDA to Phase Out Petroleum-Based Synthetic Dyes in the Nation's Food Supply, Apr. 2025. https://www.fda.gov/news-events/press-announcements/hhs-fda-phase-out-petroleum-based-synthetic-dyes-nations-food-supply
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23. Brynwood Partners / Hometown Food Company, Brynwood Acquires the Pillsbury Shelf-Stable Baking Business and Hungry Jack from J.M. Smucker (perpetual license from General Mills), 2018. https://hometownfoodcompany.com/brynwood-partners-agrees-to-acquire-the-pillsbury-shelf-stable-baking-business-the-hungry-jack-brand-and-other-assets-from-the-j-m-smucker-company/
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27. Baking Business, citing Circana, Cookie category grapples with consumer desire, value, health (52 weeks ended June 15, 2025), 2025. https://www.bakingbusiness.com/articles/64886-cookie-category-grapples-with-consumer-desire-value-health
28. Baking Business, citing Circana, Bakeries crack the code to expanding beyond the cracker market (52 weeks ended November 30, 2025), 2025. https://www.bakingbusiness.com/articles/65779-bakeries-crack-the-code-to-expanding-beyond-the-cracker-market
29. U.S. Food and Drug Administration, FASTER Act — Sesame as Ninth Major Food Allergen. https://www.fda.gov/food/food-allergies/faster-act-sesame-ninth-major-food-allergen
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