USPS Finds Reviewed Mail OK at Standard Rate
The rule change aims to clarify the circumstances in which mail containing personal information will be eligible for Standard rates rather than First Class. The rule allows "personal information" in Standard mail if:
· The mail piece contains an "explicit solicitation" for a product or service for sale or lease, or an "explicit solicitation" for a donation.
· All of the personal information is "directly related" to the advertising or solicitation.
· The "exclusive reason" for including each item of personal information is to support the advertising or solicitation in the mail piece.
Since the change was proposed last year, nonprofit mailers in particular have voiced concern because a literal application of the rule might disqualify nonprofit mail consisting of program-related content as well as a solicitation for donations.
"If your mailing is discovered to contain personal information that is not directly related to the solicitation, then you don't just pay the difference between Nonprofit Standard and commercial Standard, you pay the difference between Nonprofit Standard and First-Class mail, which can be as much as [25 cents] per mail piece," said Neal Denton, executive director of the Alliance of Nonprofit Mailers. "Multiply that by 150,000 pieces, and that starts to become real money."
Nonprofit mailing groups sent an e-mail alert two weeks ago to members, other groups and fundraisers regarding the new rule.
"Do you include any data fields in your Standard mail pieces other than the date and the name and address of the recipient?" the alert asked. "If so, your mailings may need to pay First-Class rates beginning on June 1. ... Even now - less than eight weeks before the new rules take effect - the USPS has not answered some of the most obvious and basic questions about what the new rules permit and forbid."
The alert was sent by Denton; Paulette V. Maehara, Association of Fundraising Professionals; Senny Boone, Direct Marketing Association - Nonprofit Federation; Tracy Lea, Direct Marketing Association of Washington, DC; Thomas Daubert, Direct Marketing Fundraisers Association; and Georgette Lehmuth, National Catholic Development Conference.
The message also said that representatives met with the USPS, and "in issue after issue, the USPS officials suggested that personalization would be severely restricted."
Postal officials told the representatives that decisions would be made only on a case-by-case basis upon submission of actual mail samples and further review, including matters such as segmentation by age and gender; petitions and other issue-advocacy material; references to the addressee's community; and tax receipt or tax information.
Since March 28, the postal service has received 713 submissions from nonprofit mailers or ad agencies on behalf of nonprofits. Sherry Freda, USPS manager of mailing standards, said 96 percent to 97 percent of the 500 pieces reviewed are eligible as Standard Mail as prepared.
Of the 3 percent or 4 percent that would have to mail at First-Class rates, the personal information was not associated with a solicitation for donations, said Ed Wronski, manager of the pricing and classification service center. One was an acknowledgment letter thanking a recipient for a donation and included the date the money was received, "but then they [didn't] tie it back into a solicitation," he said. Another involved a piece showing the total amount the donor gave for the previous year as well as an introduction to keep the notice as a receipt for tax purposes.
Wronski said postal officials are calling mailers immediately to explain why the pieces are eligible for Standard or First Class.
In another e-mail alert sent to members late last week, Boone said she expects problems once the rule takes effect in June.
"The heart of the problem at the moment is any mail piece that does not directly tie the solicitation for a donation to the personal information," she wrote. Other cases "will be those that do not contain an explicit solicitation for a donation in the mail piece, but include personal information which is beyond name and address, such as calls to action on a legislative matter that contains the name of an elected representative."
Melissa Campanelli covers postal news, CRM and database marketing for DM News and DMNews.com. To keep up with the latest developments in these areas, subscribe to our daily and weekly e-mail newsletters by visiting www.dmnews.com/newsletters