Revisiting an Old 'Silly Regulation'

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There is no question that First-Class mail, the U.S. Postal Service's main product, is in long-term decline. The so-called postal reform legislation does not directly address this issue. The long-term survivability of the USPS depends on its ability to react to a changing landscape of customers' needs.

The postal service's track record of reaction has not been good. I read with interest a recent notice in the Federal Register that permits "Periodicals Mail Enclosed With Merchandise [to be] Sent at Parcel Post or Bound Printed Matter Rates."

This regulatory change interests me because of a situation I encountered about 15 years ago. I was vice president of global postal affairs for a large international publisher of magazines, books, music products and videos. Permit me to tell you a story about the inane postal regulation I encountered.

My company's magazine division published a health magazine with a monthly circulation of 500,000. The magazine was about to celebrate its 10th anniversary. The plan was to develop a coordinated marketing campaign to increase both ad sales and circulation.

At the same time, the publisher's book division produced a general-interest medical book series that shipped to 100,000 customers every other month. The thought was to include a free copy of the magazine with an upcoming shipment of the book.

That co-mailing would accomplish several things. It would raise the magazine's circulation for the anniversary issue by 20 percent, making it more attractive for advertisers. It would provide a nice free premium for the book recipients, making them more likely to stay as recipients of the medical series. And some of the series recipients likely would respond to an enclosed offer to subscribe to the magazine. It seemed to be a no-lose situation, and every one of those positives would wind up increasing postal revenue.

However, after some study, I found an obscure regulation in the Domestic Mail Manual that did not permit a complete copy of a magazine to be shipped with a parcel at parcel post rates. When I asked postal officials why, I was told it would be a problem to determine how much postage to charge. I suggested that, for postage calculation purposes, the magazine be considered all advertising and just add the weight of the magazine to the weight of the parcel's merchandise to determine the postage. That seemed a simple enough solution.

I was told that though this was a logical suggestion, the regulations did not permit it. As an alternative, I was given a suggestion. The regulation did permit an incomplete copy of a magazine to ship with a parcel. My question: What is an incomplete copy?

I learned that an incomplete copy is not a copy with some advertising omitted. Regional editions of a magazine often contain different advertising, so it would be difficult for the USPS to determine whether it truly was an incomplete copy. The definition of an incomplete copy was a copy with some editorial material omitted. To meet postal regulations, we needed to go back to press to produce 100,000 copies of the magazine with several pages of editorial omitted, though these omitted pages were listed in the table of contents.

After the reprinting, out went the shipment, including the medical series book, the incomplete copy of the magazine and a letter to recipients from the book publisher announcing that the shipment included the book, a gift of a magazine to celebrate its 10th anniversary and a sentence noting that several editorial pages had been omitted to conform to postal regulations.

Readers were confused about what postal regulation required editorial material to be omitted.

It took the postal service 15 years to eliminate this silly regulation. In the world of the Internet, the USPS cannot take years to change these kinds of regulations.

Several years ago, the USPS created a joint industry task force to look at product redesign. But there were two problems. First, as one who participated with several of the sub-groups, it seemed to lack senior management support or focus. Second, redesign seemed more interested in solving operational issues than in providing opportunities to generate new mail volumes. The product redesign effort needs to be restarted, with a marketing-driven focus and real senior management backing.

It's rumored that 29 negotiated service agreements are under review by the postal service. Perhaps someone there has begun to see the light.


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