Alliance Advocates in Favor of Custom Stamps

May 26, 2020

Last week, the Alliance filed comments at the Postal Regulatory Commission in favor of retaining the customized postage program.  This allows customers to print their own custom stamps through an authorized USPS private sector partner.  Some nonprofits have found the stamps a very effective tool to increase response rates and as a brand ambassador as recipients use their stamps.

Apparently, a recent lawsuit opposing new USPS regulations banning religious images prompted the agency to throw in the towel with a proposal to kill the program.  The private sector partner, Stamps.com objected, as did the PRC Public representative and a commercial user named Minted.com.  The PRC has posed a number of questions to the USPS as a result.

Here is the timeline on filings:

 

 

 

 

 

 

 

 

Here is an excerpt from our filing:

We write to add our members’ voices to those who urge conservation of the customized postage program. We agree in particular with many of the points raised in the comments of Stamps.com. We will not repeat those arguments here. However, because the Alliance has for four decades been the leading advocate for nonprofit mailers, including some of the country’s most impactful organizations, we wish to elaborate on an important observation that Stamps.com made in its comments:

O]ur Customized Postage products are popular with nonprofit organizations that use PhotoStamps on the return envelopes they send to prospective donors to mail back donations. Nonprofits have provided positive feedback on the Program and it has helped increase the recognition of their brands and missions and made their fundraising efforts more successful. Customized Postage is used to raise money for important causes, such as helping wounded members of our military, the homeless and those living in poverty, and animal welfare. USPS benefits financially from PhotoStamps purchased by nonprofits for their fundraising campaigns because only a small portion of the recipients of fundraising letters respond, allowing USPS to keep the value of the postage that was paid but not used. Postage is at full First Class, not nonprofit postage rates. Ending the Program could result in a lower rate of return on fundraising letters, which will negatively impact the communities these nonprofit organizations serve. In light of recent developments in the world, we urge USPS not to eliminate a successful and profitable program that also helps raise money for underserved communities experiencing unprecedented financial hardship during these uncertain times.

See Stamps.com Comments at 3-4. On behalf of our members, we will amplify Stamps.com’s warning that elimination of the USPS customized postage program will harm nonprofit mailers, those organizations’ charitable missions, and the beneficiaries of their charitable works.

As we have previously explained in other filings, customized postage placed on outbound mailpieces and return envelopes can, and does, improve the attractiveness and response rate of mailings by nonprofit organizations. See Comments of Alliance of Nonprofit Mailers on Notice of Proposed Rule, Revisions to the Requirements for Authority to Manufacture and Distribute Postage Evidencing Systems; Customized Postage Products, 82 Fed. Reg. 1294 (Ltr. from D. Levy dated Feb. 12, 2017). There are several reasons why this is so:

  • First, nonprofit donors place a very high value on mail they receive that contains custom stamp packages. For many of these donors – particularly seniors – customized postage serves as a collectible. Alternatively, some donors use the postage for sending cards, paying bills, or other handy uses. As the Commission well knows, “the value of the mail service … to both the sender and the recipient” is a statutory factor that must be accounted for in this docket. See 39 C.F.R. 3040.132(b); 39 U.S.C. § 3622(c)(1).
  • Second, customized postage positively impacts nonprofits’ bottom line. A mail service provider recently compared the performance of outbound mail in which a custom stamp was paperclipped to a fundraising appeal letter and visible through the outer envelope window with mail that did not display customized postage (there were no other differences between the two mail pieces). Mail with the customized stamp had a 23 percent higher response rate, correlating to a 13 percent increase in revenue to the nonprofit organization, than mail without the customized postage.
  • Finally, customized postage has nonmonetary value for nonprofits. Custom stamps may serve as an extension of the organizations’ charitable missions. For example, the Commemorative Air Force uses custom stamps to teach Americans about the role military aviation played in winning World War II by showcasing their WWII warbirds on each stamp.

As Stamps.com noted, many nonprofit organizations utilize custom postage in fundraising appeals to raise money for causes such as helping wounded members of our military. Wounded Warrior Project (“WWP”), for example, is an organization recognized as tax-exempt under section 501(c)(3) of the Internal Revenue Code that provides critical programs and support to veterans and service members injured while serving in the military on or after September 11, 2001. Since 2018, WWP has sent Stamps.com customized First Class postage as a premium inside of 18.5 million outbound mail pieces (which are sent as nonprofit Marketing Mail). Here is an exemplar (and iconic) image of the customized postage used by WWP:

 

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