Market research industry warns the 2030 Census proposal would make the census harder to answer, less consistent in where it counts people, and less dependable as the benchmark for all statistically-representative research in the U.S.
Washington, DC – The Insights Association (IA), representing the $89.3 billion U.S. market research, insights and analytics industry, today filed comments urging the Department of Commerce and the Census Bureau to withdraw or fully reconsider the proposed 2030 Census rule (Docket No. USBC-2026-0628).
The rule, published in the Federal Register on September 10, 2026, would eliminate race and ethnicity questions from the 2030 Census and rewrite the residence criteria that determine who gets counted and where.
"When the country's core demographic data is arbitrarily diminished, and the ruleset for who gets counted and where becomes inconsistent or ambiguous, the errors will not stay in the census," said Howard Fienberg, Senior VP Advocacy at the Insights Association. "They will rush downstream into every dataset calibrated to it."
Losing the industry's yardstick
The proposal would leave the 2030 Census without a race question for the first time since 1790, and would drop the Hispanic-origin question asked since 1970. The Insights Association told Commerce Secretary Lutnick that census race and ethnicity data are a key statistical benchmark -- alongside age, sex, education and geography -- against which virtually every representative study in the U.S. is designed, weighted and validated.
"No private data source -- commercial, administrative, or otherwise -- can substitute for the Census Bureau's constitutionally-mandated universal enumeration," said Fienberg. "Take away the benchmark, and researchers lose the ability to know, let alone even correct for, whether their samples over- or under-represent any given group."
IA's comments detail the real-world business decisions that rest on that benchmark, such as:
- Audience measurement "currency": Firms like Nielsen project TV, streaming and digital audience samples to the full U.S. population using census-derived controls, producing the ratings against which the multi-billion-dollar ad marketplace is priced.
- Market sizing and ad budgets: Estimates such as the 62.5 million-person Hispanic consumer segment, with $2.2 trillion in buying power, are anchored to census data and directly inform media buying.
- Product and concept testing: Nationally-representative quota samples behind go/no-go launch decisions depend on an accurate population baseline.
- Marketing-mix modeling, retail site selection and polling: Each uses census-derived population data to separate real effects from underlying demographic composition.
IA warned that dropping the questions would permanently degrade survey weighting and sampling nationwide, raise costs for businesses that depend on accurate insights, and erode public trust in research. As AI systems increasingly shape commercial and public decisions, IA noted, authoritative population benchmarks are becoming more important, not less.
IA's comments build on joint comments led by IA and filed today by 14 U.S. business organizations specifically opposing the elimination of race and ethnicity questions. The signers -- including the American Association of Advertising Agencies (AAAA), Association of National Advertisers (ANA), Interactive Advertising Bureau (IAB), National Retail Federation (NRF), Nielsen, the United States Hispanic Chamber of Commerce and others -- urged the Department to withdraw or substantially revise the rule and keep both questions on the 2030 Census.
Residence rules that would muddy the count
The Insights Association also objected to changes in how the census decides where people live, warning they would raise respondent burden and introduce errors that ripple into a decade of data. IA urged the Bureau to:
- Keep April 1 as Census Day. The rule would replace it with a January 3–April 1 "enumeration period," assigning people to wherever they spent the most days, with as little as one hour counting as a day. IA noted that research subjects struggle to recall that level of detail, especially when one person answers for an entire household.
- Keep counting college students where they live. Under the proposal, students claimed as tax dependents would likely be counted at their parents' homes, distorting local data on 18-to-24-year-olds in both college towns and hometowns.
- Restore clear rules for group quarters. The 2020 criteria covered more than 20 residence situations; the proposal covers eight, leaving out nursing homes, dormitories, shelters, group homes, treatment facilities, foster care and other situations.
- Not rely on tax records to determine residence. Tax addresses often reflect mailing addresses, PO boxes, preparers or payroll offices, and many people, including lower-income households, older adults and students, don't file at all.
- Clarify that any reduced count applies only to apportionment. IA has no stake in apportionment, but excluding millions of residents from the total headcount would leave every downstream benchmark short of the real population.
An accurate picture of America
"A representative democracy and a functioning economy depend on an accurate picture of the people they serve," said Fienberg. "When people and communities disappear from the benchmark, they become easier to miss in the decisions informed by it."
IA's filing follows its August 25, 2026 letter to Secretary Lutnick on the race and ethnicity question, prior to the introduction of the proposed rule. The association offered to meet with the Secretary or his staff to discuss the practical implications of the proposal for American businesses and the broader data ecosystem.
Read IA's full comments.
About the Insights Association
The Insights Association (IA) is the leading trade association for the market research, insights and data analytics industry in the United States, with more than 9,300 members. IA's members produce the intelligence, analytics and insights that define the needs, attitudes and behaviors of consumers, organizations, employees, students and citizens, across every sector of the American economy. Learn more at insightsassociation.org.
About the Author
Based in Washington, DC, Howard is the Insights Association's lobbyist for the marketing research and data analytics industry, focusing primarily on consumer privacy and data security, the Telephone Consumer Protection Act (TCPA), tort reform, and the funding and integrity of the decennial Census and the American Community Survey (ACS).
Howard has more than two decades of public policy experience. Before the Insights Association, he worked in Congress as senior legislative staffer for then-Representatives Christopher Cox (CA-48) and Cliff Stearns (FL-06). He also served more than four years with a science policy think tank, working to improve the understanding of scientific and social research and methodology among journalists and policymakers.
Howard is also co-director of The Census Project, a 900+ member coalition in support of a fair and accurate Census and ACS.
He has also served previously on the Board of Directors for the National Institute for Lobbying and Ethics and and the Association of Government Relations Professionals.
Howard has an MA International Relations from the University of Essex in England and a BA Honors Political Studies from Trent University in Canada, and has obtained the Certified Association Executive (CAE), Professional Lobbying Certificate (PLC) and the Public Policy Certificate (PPC).
When not running advocacy for the Insights Association, Howard enjoys hockey, NFL football, sci-fi and horror movies, playing with his dog, and spending time with family and friends.