CRCA Update: USPS Ponders paper-only Marketing Mail

October 10, 2018

By Phil Claiborne, Circulation Director, Elks Magazine

The United States Postal Service is “contemplating” ridding Marketing Mail of merchandise or goods, only paper-based printed matter would be allowed.  First, let me say I dislike the name Marketing Mail, for its commercial connotation, I prefer Standard Mail. Second, what does this mean for nonprofit fund-raising mail?  I did a quick survey of our organization’s mail and discovered many would be disallowed; plastic membership cards -disallowed; return address stickers, a front-end premium -disallowed; T-shirts, another front-end premium -disallowed; holiday cards sent in lots of ten, -disallowed, and so on.  Surely this is a mistake, I thought.  And it may be.  Read on.

Keeping a close watch on developments, I noticed my fellow nonprofit mailers were reacting well to the call for action.  You see, the USPS’ announcement of “contemplation” was made in the August 23rd in the Federal Register, a means of notification many of us monitor for “official” announcements, many which often call for a comment period.  In this case comments are open until October 22nd.   As of the recent USPS Mailer’s Technical Advisory Committee meeting October 3rd there were as many as 3,600 commenters.  That’s atypically a lot.

Along the way, I read an article in The NonProfit Times referring to the Alliance of Nonprofit Mailer’s comments, including an explanation of “Title 39 USC §§ 3626(a) and (m) which entitle nonprofit mailers to mail products at nonprofit Marketing Mail rates,” plus and explanation of Title 39 Third Class Mail limits prior to 1970, involving personalized communication intended for First Class Mail, the exclusion of Periodicals Mail and a 16 oz. weight limit.

I attended the Mailer’s Technical Advisory Committee with great anticipation of a clarification by the USPS, and possibly a roll-back of their initial “contemplation.”  I got neither.  I should say, “we” got neither because the scope and scale of USPS intentions are immense, even gargantuan and almost hilariously so in its negative impact on charitable fund raising.  What we got was an admission by the USPS that the Federal Register Notice was a mistake, not that their contemplation of an illegal rule change was a mistake but that their engagement with mailers in this way, was a mistake, and this is where the momentum of good will left the tracks and put us in the ditch.

It turns out, the target of the USPS’ contemplation is commercial product fulfillment mail, the type in which you order a product through the mail or online and it is shipped to your mailbox. These are obviously small items, consistent with the tactile limits of Marketing Mail.  There are limitations in efficiently processing this mail which suggests an examination of mailing standards and pricing of certain types of Marketing Mail.  Instead of proceeding normally, the USPS has decided to attack the content of mail, a different approach entirely, and accidentally put nonprofit fund-raising mail in their sights.

The question is now, what to do?  The USPS refuses to reshape or limit their proposal, for now, and proceed with tabulation of rule-making comments.  To the hundreds of nonprofit mailers and their mail industry suppliers who have taken time evaluate and enumerate the possible devastation wrought by this USPS contemplation I congratulate you for stepping up.  Our rights are taken for granted until we defend them.

The Postmaster General has promised to engage in this discussion going forward, through an MTAC group and the like.  I suggest she has awakened a force of immense political power, one that is best engaged before we have our coffee and take on the real challenge of the day, our varied and true charitable missions.

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