Doc #1: MTAC Task Team 27 Communication Document – February 22, 2019

 This document is intended to help communicate and socialize to a broader community within the mailing industry the potential next steps in addressing the Advance Federal Register Notice (AFRN) on potential changes to Marketing Mail content.  This AFRN was issued by the Postal Service August 23, 2018 and requested feedback from the mailing community.

The stated goals of the AFRN were:

• Facilitate levels of service expected for the processing and delivery of merchandise that include end-to-end tracking and visibility.
• Move fulfillment of merchandise and goods out of USPS Marketing Mail consistent with transfer of Commercial fulfillment parcels out of Marketing Mail.
• Reduce operational inefficiencies when machines are unable to process letter-size or flat-size shaped inflexible items.

There were nearly 4,700 comments on the AFRN received from mailing associations, printers, mail service providers, non-profit organizations, marketing services, magazine publishers, elected officials, and concerned citizens.

• Over 4,300 comments originated from the American Legion (Local organizations & individual members)
• Over 300 comments on mailability concerns:
• Non-paper products Plastic card (i.e., gift cards, loyalty cards, memberships cards), CDs / DVDs, Coins, Keychains, Pens, Fabric.
• Premiums: Non-Profit – Encouragement or thank for giving; Magazine – encouragement or thank for subscribing.
• Limitations will drastically impact the use of mail; alternative postal offerings not financially feasible.
• A few individuals supported the intent of the AFRN: mail box clutter; didn’t ask for items sent in the mail.

MTAC Task Team #27 was created to determine next steps in addressing issues.

• Postal Service and Mail Industry personnel are actively participating since early January 2019

Potential next step for discussion is to limit the activity to three specific areas:

1. Clarification of Existing Requirements: The Postal Service will provide clarification within the Domestic Mail Manual (DMM) of existing eligibility requirements of Marketing Mail Letters and Flats as it relates to what are the characteristics that make a mail piece a letter, flat, parcel, and the qualifications to be machinable and/or qualify for automation eligibility.

2. Machinability of Letters & Flats: The Postal Service will focus efforts on identifying and addressing inefficient mailings. Using data analysis and physical verification of mailings and mail characteristics, the Postal Service will identify customers providing inefficient and/or non-machinable volumes and address them directly.

Non-fulfillment mailpieces that meet the existing mailability, machinability, and automation requirements will continue to be allowed to be mailed regardless of content.  This includes traditional Marketing Mail letters & flats (direct mail envelopes, cards, flyers, catalogs, newsletters) as well as, mailpieces with content that include non-paper items such as (not inclusive):

• Plastic cards (i.e, gift cards, loyalty cards, memberships cards)
• Coins/tokens
• Fabric
• Keychains
• Pens
• Labels
• Bookmarks
• Pins
• Other promotional items

3. Fulfillment: The Postal Service currently does not allow fulfillment within its commercial Marketing Mail Parcel product offering (see DMM 243.3.2.2). Fulfillment is defined as the sending of items specifically purchased or requested by the customer of a mailer.

The Postal Service would like to evaluate the impact of expanding the limitation of fulfillment (as defined within Marketing Mail parcels) to the letter and flats shape Marketing Mail. The proposed new regulation (below) for letters and flats responds to mailer concerns by limiting the impact on current uses of Marketing Mail, while blocking the types of fulfillment that would most naturally be sent as parcels. It is expected that any changes of this nature would require approval from USPS Management, Governors and the Postal Regulatory Commission.

 Proposed New Regulation

Marketing Mail Letters & Flats

Marketing Mail Letters and Flats cannot be used for fulfillment purposes (i.e. the sending of items specifically purchased or requested by the customer of a mailer) with the exception of:

A – Fulfillment items used for promotional purposes

B – Fulfillment items which are primarily paper-based.

A – Promotional Fulfillment – Promotional fulfillment items will be allowed to be mailed as a Marketing Mail letter or flat.  Promotional fulfillment items are defined as items fulfilled for promotional purposes and are often used to strengthen relationships with existing or prospective customers, donors, or clients.   Although the items may be requested these promotional fulfillment activities are secondary to a primary non-fulfillment transaction or engagement (i.e., the donation of gift/ money, a paid subscription to periodical, etc.) between an organization and customer.

Examples of promotional fulfillment include:

• A charity or non-profit organization sending a gift or promotional item to a supporter as a thank-you for a donation. These gifts or items are often called “premiums”.
• A publisher sending a requested gift to a person who has recently started or renewed a subscription to their magazine.
• The sending of a product sample to prospective customers of that product

Regardless of content, these promotional fulfillment items must meet the appropriate Marketing Mail requirements for processing and rate category eligibility.

B – Fulfillment of primarily Paper-based items – Fulfillment of primarily paper-based items will be allowed to be mailed as a Marketing Mail letter or flat. These include items which have been requested or purchased that are primarily paper-based.  The items being fulfilled may include (not inclusive):

• Publications
• Magazines
• Catalogs
• Directories
• Prospectuses,
• Checks
• Mailing labels,
• Note/greeting cards
• Note pads
• Calendars
• Membership cards
• Other paper-based items

Regardless of content, these paper-based fulfillment items must meet the appropriate Marketing Mail requirements for processing and rate category eligibility.

Doc #2: MTAC Task Team 27 – Closing Statement & Recommendations

Task Team 27 met weekly from January 4 through February 22 to review/refine the August 2019 AFRN concerning Marketing Mail content.  The scope of this TT was to further define the USPS proposal to limit the scope of products which may be considered in the future ineligible for Market Dominant Marketing Mail rates.

The discussions focused on 2 main topics:

• Mailpieces currently in the mail stream for which automation rates are being claimed however at the individual plant levels, appear to be handled in manual processes
• The desire to further define Marketing Mail to exclude fulfillment pieces, which would likely require those pieces to be presented as parcels in the United States Postal System. By requiring these pieces to mail as parcels, the mailing consumer would be guaranteed the ability to track these fulfillments product to final delivery.

The TT discussed those pieces may not run efficiently or effectively on postal equipment.  The TT recommended, using data, to identify these pieces in the mailstream, confirm in fact at the plant levels they will not run on automation equipment, and work with these individual mail owners to correct the package design.

The TT recommended a review of machinable characteristic requirements for both letters and flats to verify they meet the needs of all postal equipment in use.  During these discussions the TT also identified confusion in the DMM definition/specification of qualified machinable flat mail piece designs.  This definition of a machinable flat mail piece should be reviewed.

The TT discussed how to provide more clarity and definition for mailpieces that would not be impacted by the intent of the AFRN as well as for those identified fulfillment mailpieces that may potential be impacted.  It was not the intent of this AFRN to limit the ability of customers mail items such as premiums, faux cards, coins, etc. which marketers use to either entice response or thank a consumer for a purchase or donation.  The Postal Service goal has been to facilitate efficient processing of letter and flats mail pieces and also maintain a high-quality brand value in the shipping industry by ensuring the shipping expectations of ecommerce consumers are met.

Recommend the Postal Service proceed to do the following:

3. Clarification of Existing Requirements: Provide clarification within the Domestic Mail Manual (DMM) of existing eligibility requirements of Marketing Mail Letters and Flats as it relates to what are the characteristics that make a mail piece a letter, flat, parcel, and the qualifications to be machinable and/or qualify for and automation eligibility.
4. Machinability of Letters & Flats: Focus efforts on identifying and addressing inefficient mailings. Using data analysis and physical verification of mailings and mail characteristics, the Postal Service will identify customers providing inefficient and/or non-machinable volumes and address them directly.
5. Definition of Fulfillment: Recommend to the Postal Service to obtain additional industry input, prior to implementing any changes regarding the limitation of the use of fulfillment in Marketing Mail.  It is encouraged that another MTAC task team be established to help the Postal Service evaluate the full impact of the implementing the newly defined proposed fulfillment limitation to Marketing Mail letters and flats.
6. Communication to Industry – Recommend that the Postal Service provide clarity to the mailing industry on the status of the AFRN. This includes developing a communication message to be shared with the mailing industry that refines (and narrows) the scope and impact of any potential changes to be made within Marketing Mail.