USPS Test Leads to Testy Mailers

On the surface, it seemed like a harmless little experiment. But a July request by the U.S. Postal Service for a one-year test of the use of repositionable notes (RPNs, more commonly known as Post-It notes, 3M’s brand name) on the covers of catalogs and magazines has turned controversial.

That’s because the USPS wants to be able to tack a $0.015 surcharge for each Standard Mail flat piece affixed with an RPN for the test — and impose a permanent surcharge if the test is a success — even though the agency admits that it incurs no additional costs to handle such mail. What’s more, some mailer advocates argue that there’s really no need for a test anyway, given that there’s nothing in the Postal Service’s rules manual that prohibits catalogers or publishers from affixing RPNs on their covers right now.

On Aug. 11, a coalition of mailer groups, including the Association for Postal Commerce (PostCom), the Direct Marketing Association, and the Mailing & Fulfillment Service Association, filed a joint motion to dismiss the case outright. On Aug. 27, the Postal Rate Commission (PRC) turned down the motion and proceeded with the case. As of early September, the PRC was expected to rule on the proposal by October.

“We don’t like the premise upon which this test is based,” says PostCom president Gene Del Polito. “We didn’t think it was legal, but the PRC overruled us.”

In rejecting the mailers’ bid to dismiss the test, the PRC said that the 1970 Postal Reorganization Act, the law that dictates how postal rates are set, “does not forbid rate elements to be based primarily on characteristics other than cost.” For instance, rates for magazines are lower than those of catalogs, reflecting “distinctions in social value,” according to the law. It costs the USPS no more to deliver, say, a 64-page, 8-1/2″ × 10-1/2″ catalog to a given address than it does to deliver a magazine of the same dimensions.

The brouhaha about the extra cost may end up being academic. Currently no catalogers or magazines are known to use RPNs on their covers. Joe Schick, director of postal affairs for printer Quad/Graphics and a member of the joint USPS-industry Mailers Technical Advisory Committee, says that one catalog client had agreed to take part in the test but quickly backed out upon learning of the cost.

Besides, Schick says, catalogers have used air stickers (also known as dot whacks) “for many years to accomplish the same thing — at no extra cost.”

The USPS, continues Schick, “is so focused on trying to gain revenue that it lost track of what it should be going after, which is more mail volume.” Rather than building business, the Postal Service “could wind up driving catalogers to newspapers for inserts rather than going in the mail.”

For his part, PostCom’s Del Polito is concerned that a surcharge on RPNs will set a dangerous precedent. If the Postal Service can charge mailers for RPNs on catalog covers, “then it could evolve to being any outserts, and we don’t want to go down that road,” he says.

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