Cookie and Cracker Manufacturing (U.S.) — NAICS 311821

An investor's primer. NAICS = North American Industry Classification System, the federal code used to define an industry.

1. Overview

This is the business of baking shelf-stable sweet and savory biscuits at industrial scale — Oreos, Chips Ahoy!, Ritz, Wheat Thins, Triscuit, Goldfish, Cheez-It, Keebler, Milano, saltines, graham crackers, and the store-brand versions of all of them. It is a mature, high-volume, low-priced consumer-staple category: Americans buy cookies and crackers in good times and bad, which makes the underlying demand unusually steady, but growth is slow and the game is won on scale, brand strength, and cost control rather than expansion.

Why an investor cares: it is a defensive, cash-generative corner of packaged food with a few dominant brands that carry real pricing power, wrapped around a fragmented base of contract and private-label bakers. Reported U.S. manufacturer shipments were about $10.3 billion in 2022 [1]; measured at retail (where brand markups and store margins are added), the U.S. cookies-and-crackers market is roughly $22 billion in 2025 [2]. Circana scanner data for the 52 weeks ended December 29, 2024, recorded $14.7 billion in cookie retail sales and $11.0 billion in cracker retail sales across measured multi-outlet and convenience channels [3].

Public vs. private ways in: there is no U.S.-listed pure play. The largest listed proxy is Mondelez International (which owns Nabisco), followed by The Campbell's Company (Goldfish, Pepperidge Farm) and, more diluted, General Mills, J.M. Smucker, and Flowers Foods. Much of the sector is now privately held — Ferrero (Keebler, Famous Amos), Mars (which absorbed Cheez-It and Club owner Kellanova in December 2025), and family-owned bakers and private-label contract manufacturers. Private and public routes are both covered in Section 10.

2. What it is, and how it's structured

Scope (what NAICS 311821 covers): factories primarily making cookies, crackers, and closely related baked items — sweet biscuits, filled cookies, wafers, saltine/soda crackers, graham crackers, and even ice-cream cones [4].

What it excludes (important, because adjacent products look identical on a shelf):

• Bread, rolls, cakes, pies, and fresh in-store/retail bakery cookies → NAICS 311811/311812/311813 (Bread and Bakery Product Manufacturing). A cookie baked in a supermarket's own bakery is not counted here.
• Pretzels (except soft), corn/potato chips, extruded snacks, popcorn → NAICS 311919 (Other Snack Food Manufacturing). This is why Frito-Lay chips and Snyder's pretzels sit outside this code even though they share the snack aisle.
• Dry pasta and dough/flour mixes → NAICS 311824 (its sister code within the 31182 group) [4].

The manufacturing process: A conventional plant receives flour, sugar, oils, cocoa, dairy ingredients, inclusions, leavening agents, and packaging materials in bulk; weighs and mixes them into dough; forms the dough by sheeting, cutting, molding, extrusion, or depositing; bakes it in continuous ovens; cools, coats, or sandwiches the product where applicable; and packages and case-packs it. Cracker lines may add fermentation, lamination, oil spraying, and salting. Sanitation, allergen segregation, quality control, and equipment maintenance run across the entire process [5][6].

Ownership mix: a barbell. At one end, a handful of large corporations own the branded, nationally advertised lines that command shelf space. At the other end, dozens of mid-size and small contract manufacturers ("co-packers") and private-label bakers produce store brands and make product under license — for example, the two bakeries licensed to make Girl Scout Cookies (ABC Bakers, owned by Interbake Foods; and Little Brownie Bakers, owned by Ferrero) [7]. This structure matters for the concentration math in Section 8.

3. How big it is

Federal figures (prefer these):

(SBA = U.S. Small Business Administration; its 1,250-employee ceiling for this code means a "small" cookie/cracker maker can be quite large — most of the 386 firms qualify.)

Undercount and scope caveats (read this before using the size figures). These are manufacturer numbers and they capture the factory base fairly completely — this is a capital-intensive industry dominated by large, well-surveyed firms, not one hidden among tiny or informal operators. But the $10.3 billion understates how much economic activity the category represents, for three honest reasons: (a) it is measured at the factory gate, before the roughly 2x markup added at retail — hence the ~$22 billion retail figure [2]; (b) cookies baked in supermarket in-store bakeries and by fresh commercial bakeries are counted under different NAICS codes [4]; and (c) popular imported biscuits (Lotus Biscoff, McVitie's, Tim Tam) are consumed here but manufactured abroad, so they never enter this code at all. Treat $10.3 billion as U.S. factory output, not U.S. consumption.

4. The investable universe

There is no listed U.S. pure play in cookies and crackers; investors buy diversified food companies for which this is one segment. Approximate scale figures are company- or segment-wide, not the 311821 slice alone.

Public companies (branded owners):

Major private / no-longer-listed owners (a large share of the category):

• Ferrero (private, Italy) — Keebler, Famous Amos, Mother's, Murray's, plus Little Brownie Bakers (Girl Scout Cookies). Built via a $1.3B purchase of Kellogg's cookie business in 2019 [16].
• Mars (private) — became a top cracker owner by acquiring Kellanova for ~$35.9B, closed December 2025: Cheez-It, Club, Town House, Carr's (U.S.), Zesta, Kellogg's Grahams [17].
• McKee Foods (family-owned) — Little Debbie (mostly snack cakes, adjacent) and some cookies/granola; ~$2B revenue, ~6,600 employees [18].
• TreeHouse Foods — private-label manufacturer; acquired by Investindustrial in February 2026, no longer publicly traded [19].
• Leclerc (family-owned, Canada) — private-label and branded cookies/crackers.
• Shearer's (CD&R-backed) — branded and private-label snack manufacturing.
• Interbake Foods / ABC Bakers and other contract and private-label bakers — produce store brands and licensed product; individually invisible on shelves.

Takeaway: to own this industry through the public market you accept dilution — you are buying a big food company for which cookies/crackers is one of several segments. Concentrated exposure (Ferrero, Mars, the private-label bakers) is only reachable privately.

5. How the money works

Cookie and cracker economics are classic high-volume, capacity-driven manufacturing, not restaurant or retail unit economics. Owners make money on four levers:

1. Input costs vs. price. The dominant swing factor is the cost of commodity inputs — wheat flour, sugar, edible oils/fats, and (for chocolate and filled products) cocoa — which together run roughly 40–50% of cost of goods [20]. Products are cheap per unit and shelf-stable (months of shelf life, low spoilage), so the fight is over gross margin: hold or raise price while managing ingredient inflation through hedging, reformulation, and pack-size changes ("shrinkflation"). An older USDA decomposition underscores processing dominance: in 2007, farm production accounted for only 2.3 cents of the bakery-products food dollar, while processing accounted for 37.7 cents [21].
2. Volume and capacity utilization. Lines are automated, continuous, and capital-intensive; profitability rises when expensive ovens and packaging lines run full. Throughput per line and utilization matter more than store count. Frequent flavor, package, or allergen changeovers sacrifice capacity through cleaning and setup time.
3. Brand pricing power vs. private label. A billion-dollar brand (Oreo, Ritz, Goldfish, Cheez-It) earns a premium price and guaranteed shelf space; a private-label saltine competes almost purely on cost. The same factory skill produces both, but the margin gap is enormous — branded owners spend heavily on advertising and trade promotion to defend it, while contract/private-label bakers accept thin margins for steady volume. Circana data 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%) [3].
4. Distribution scale. Some lines go through warehouses; others (Lance crackers, for instance) use direct-store-delivery to control shelf placement. Scale in procurement and distribution is a real moat for the leaders.

Hedging and cost pass-through: Campbell hedges exposures including wheat, natural gas, diesel, soybean oil, cocoa, aluminum, soybean meal, and corn, generally for periods extending up to 18 months [12]. Mondelez reported higher 2025 costs for cocoa, dairy, packaging, edible oils, and nuts, partly offset by lower sugar, grain, and energy costs [10]. Wheat alone is not a reliable margin proxy: USDA's average all-wheat farm price fell from $8.83 per bushel in 2022 to $6.96 in 2023 and $5.55 in 2024, but flour conversion, other ingredients, packaging, labor, and distribution can move differently, and hedges delay transmission [22].

Segment profitability illustration: Campbell's broader Snacks segment — cookies, crackers, chips, pretzels, fresh bakery, and other snacks — generated $4.2 billion of fiscal-2025 sales and $560 million of segment operating earnings (~13% segment margin), down from $4.4 billion and $648 million in fiscal 2024. Campbell attributed the decline to inflation and supply-chain costs, unfavorable volume/mix, and higher marketing, partly offset by productivity and cost savings [23]. This is an imperfect proxy: no authoritative standalone gross, EBITDA, or operating margin for NAICS 311821 alone was established.

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 snacking and pantry staples. Cookies and crackers are inexpensive, storable, and impulse-friendly — "permissible indulgence." Baseline demand tracks population and snacking occasions and is very stable.
• Price and the economy. In downturns and inflation, shoppers trade down from name brands to private label, shifting who profits more than how much is sold.
• Kids and lunchboxes / seasonality. Goldfish, grahams, sandwich crackers, and the annual Girl Scout Cookie season are demand anchors; holidays add seasonal peaks. Demand is fairly balanced through the year, with some fourth-quarter holiday benefit [10].
• Health and "better-for-you." Steady pull toward reduced-sugar, whole-grain, gluten-free, higher-protein, and "clean-label" versions — a headwind for classic recipes and a growth lane for reformulated and startup brands. New cracker launches between April 2023 and March 2024 included non-GMO claims on 42%, no-additive/no-preservative claims on 37%, gluten-free claims on 24%, vegan claims on 23%, and organic claims on 12% (shares of launches, not sales) [24].
• GLP-1 weight-loss drugs (a genuine new headwind). Glucagon-like peptide-1 medications (Ozempic, Wegovy, Zepbound) suppress appetite; studies and company commentary in 2025 pointed to households on these drugs cutting snack spending materially, with cookies and sweet baked goods among the hardest-hit categories [25]. This is the first structural demand risk the category 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%; price per unit rose 1.7% [26]. For the 52 weeks ended November 30, 2025, cracker sales slipped 1% to just under $11.1 billion, with units down 2.4% [27]. Positive dollar sales can mask declining physical volume and operating leverage.

7. Regulation

Product regulation is meaningful but manageable; the recent action is in ingredients and labeling.

• Food safety. Plants operate under the FDA (U.S. Food and Drug Administration) and the Food Safety Modernization Act (FSMA), which requires written preventive-controls plans, hazard analysis, process/sanitation/allergen controls, supplier verification, and recall procedures [28]. Recalls happen — often for allergen mislabeling (wheat, milk, egg, soy, tree nuts are core ingredients) or contamination.
• Sesame as ninth allergen. Sesame became the ninth legally recognized major food allergen effective January 1, 2023, adding labeling and segregation requirements for products containing it [29].
• Trans fats — done. The FDA ruled partially hydrogenated oils (PHOs) are no longer "Generally Recognized as Safe"; they have been effectively removed from the food supply, and the industry reformulated years ago [30].
• Red No. 3 — phasing out. In January 2025 the FDA revoked authorization for FD&C Red No. 3 in food, giving makers until January 15, 2027 to reformulate — directly relevant to colored cookies, icings, and fillings [31].
• Broader synthetic-dye phase-out. Under the 2025 "Make America Healthy Again" (MAHA) initiative, HHS (Health and Human Services) and the FDA are pressing industry to voluntarily eliminate the remaining petroleum-based dyes (Red 40, Yellows 5/6, Blues 1/2, Green 3) by end of 2026 [32]. Expect reformulation costs and natural-color substitutions across colored SKUs.
• Sodium targets (voluntary). FDA's voluntary Phase II draft guidance uses a 2022 sales-weighted cracker baseline of 545 milligrams of sodium per 100 grams, versus a proposed target mean of 380 milligrams and upper bound of 580 milligrams. These remain voluntary draft targets, not mandatory limits [33].
• Labeling. Nutrition Facts (including the "added sugars" line), allergen declarations, and bioengineered-food disclosure all apply. Possible future front-of-pack labeling is a watch item.
• Commodity/trade policy. The USDA sugar program keeps U.S. sugar prices above world levels (a structural cost for sweet biscuits), and tariffs on imported inputs like cocoa can raise costs.

None of this is existential, but the 2026–2027 reformulation deadlines are a real near-term cost and execution burden, heaviest for brightly colored products.

8. Competitive dynamics and consolidation

Two different concentration pictures — hold both in mind.

• At the factory level, the industry looks only moderately concentrated: the top-4 firms make about 38% of shipments, top-8 about 56%, and the Herfindahl-Hirschman Index (HHI, a standard concentration gauge; below 1,500 is "unconcentrated" under federal merger guidelines) is just 523.9 [1]. That low number reflects the wide base of contract and private-label bakers.
• At the brand/shelf level, ownership is far more concentrated: a short list of owners — Mondelez, Campbell's, Ferrero, and now Mars — controls the leading national brands consumers actually reach for. Circana data shows Nabisco alone at 30% of cookie retail sales and Cheez-It plus Nabisco commanding roughly 29% of cracker retail sales [3].

Consolidation has been intense and recent:

• Ferrero bought Kellogg's cookie business (Keebler, Famous Amos, Mother's) for $1.3B in 2019 [16], and continues to expand in U.S. sweets.
• J.M. Smucker acquired Hostess Brands (bringing Voortman cookies) for $5.6B in 2023 [15].
• Mars acquired Kellanova for ~$35.9B (closed December 2025) — instantly making Mars a top cracker owner (Cheez-It, Club, Town House) alongside its confectionery empire [17].
• Flowers Foods acquired Simple Mills for $795 million in February 2025, adding a better-for-you cracker and cookie brand [14].
• TreeHouse Foods was acquired by Investindustrial in February 2026, taking a major private-label manufacturer private [19].

Barriers to entry for the branded tier are high: entrenched brand equity, retailer shelf-space relationships, capital-intensive automated lines, and scale in buying flour/sugar/cocoa and in distribution. Barriers are low for the private-label/co-pack tier, which is why that base stays fragmented and margins there stay thin. New-brand disruption happens mostly in "better-for-you" niches, which the majors then acquire.

9. Risks

• Input-cost volatility. Cocoa prices spiked sharply in 2024–2025, alongside swings in wheat, sugar, edible oils, butter, and eggs; margins compress when makers can't pass costs through [20].
• GLP-1 demand erosion. The most-watched structural risk — appetite-suppressing drugs pulling snack volume out of the category over time [25].
• Volume decline despite dollar growth. Recent Circana data shows unit sales falling even as dollar sales edge up — positive revenue can mask deteriorating physical volume and operating leverage [26][27].
• Reformulation cost and execution. Meeting the Red No. 3 (2027) and broader dye phase-out (2026) deadlines requires reformulating colored products without hurting taste or shelf life [31][32].
• Private-label trade-down. In downturns, branded owners lose share to store brands — good for the co-pack base, bad for brand margins.
• Retailer power. Walmart, Costco, and Amazon squeeze pricing and can favor private label. Campbell disclosed that its five largest customers represented approximately 47% of consolidated fiscal-2025 sales, with Walmart alone at approximately 21% [12].
• Food-safety recalls. Allergen or contamination recalls carry cost and brand damage (e.g., a 2023 Goldfish recall) [12].
• Manufacturing hazards. Hot ovens, moving conveyors and cutters, repetitive work, and combustible flour/sugar/starch dust are workplace risks. BLS reported a 2024 total-recordable injury rate of 2.6 cases per 100 full-time workers for NAICS 311821 [34]. OSHA identifies food and agricultural powders as combustible-dust hazards [35].
• Slow top-line growth. Even absent shocks, this is a low-single-digit category (forecasts cluster near ~3% annual growth) [2] — value comes from margins, cash, and consolidation, not expansion.

10. How to invest, and the outlook

Public routes. The cleanest listed exposure is Mondelez (MDLZ) — its Nabisco biscuit/cracker portfolio is the largest single collection of U.S. brands in this code, and its global Biscuits segment is the biggest slice of the company [10][11]. Campbell's (CPB) is the next-best proxy through Goldfish, Pepperidge Farm, and Lance [12][13]. Flowers Foods (FLO) offers growth-oriented exposure through Simple Mills, though accompanied by a much larger bread business [14]. General Mills (GIS) and J.M. Smucker (SJM) give diluted exposure. For foreign-listed options, Lotus Bakeries (Biscoff) and Grupo Bimbo are available. In every case you are buying a diversified food company, with the usual staples characteristics — dividends, defensiveness, modest growth — rather than a bet on cookies alone. (Tickers and any valuation work belong to individual security analysis, not to this industry view.)

Private routes. This is where concentrated exposure lives. Much of the category is held by Ferrero and Mars (both private) and by family-owned and PE-backed contract manufacturers and private-label bakers. Private-equity roll-ups of co-packers, and venture/growth investment in "better-for-you" biscuit startups (reduced-sugar, gluten-free, high-protein) that the majors later acquire, are the main private avenues. Girl Scout Cookie production, notably, runs entirely through two privately held bakers [7]. Key underwriting variables: brand velocity, retailer concentration, contract duration and commodity pass-through; plant utilization and bottleneck capacity; allergen and recall history; maintenance capex; dependence on a few lines or facilities; SKU complexity; labor stability; and whether intellectual property, customer ownership, and manufacturing assets sit in the same entity.

Near-term drivers to watch (forward-looking):

• Whether volume stabilizes as inflation eases against the GLP-1 drag on snacking [25].
• Cocoa and grain costs normalizing — the swing factor for 2026 margins [20].
• Execution on dye reformulation ahead of the 2026–2027 deadlines [31][32].
• Private-label share — still gaining, pressuring branded margins.
• More consolidation in the wake of the Mars–Kellanova deal, as scale in snacking keeps being rewarded [17].

Bottom line: a defensive, cash-rich, slow-growing manufacturing category where the money is made on input-cost management, capacity utilization, and brand pricing power, the leaders are increasingly private after a wave of mega-deals, and the two things that could reset the trajectory are GLP-1 drugs on the demand side and cocoa/ingredient inflation plus reformulation on the cost side.

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Sources

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