How the USPS’s Proposed Changes to Marketing Mail Hurts Customers

Written by Phil Thompson
on October 02nd, 2018 in All, Leading Change

On August 23, the United States Postal Service filed a Federal Register with proposed changes to the definition of Marketing Mail Contents. This proposal has mailers at all levels very concerned, regardless of industry. Members of the USPS state that their goal is to open a conversation about what Marketing Mail is, and to look at ways to improve efficiency and operations in the future.

Unfortunately the USPS did not communicate this goal in the Federal Register, nor in their follow-up message. Instead the USPS proposes substantial changes for discussion; for example only paper-based mail — no polybags, to be implemented no sooner than 2020. I would have expected that a CMO or Postmaster General would have stopped a communication that is challenging their largest product — but this did not happen.

Below is a letter signed by 18 associations asking the PMG to retract this Federal Register and engage the mailing community in a larger discussion. What’s interesting is that a number of these associations do not have substantial “skin in the game” with Marketing Mail — but they recognize how attacks on the largest USPS product will have impacts on prices and services standards for their products. Quad/Graphics congratulates each of these associations who have joined together for the common good.

This document shows there’s widespread concern for the actions of the USPS from all segments of the mailing industry. Quad will file comments in October, but hopes the PMG sees merit in this letter and withdraws the proposal. In the meantime, we continue to offer guidance to our clients for how to respond, and how to be proactive.

To file comments and read the proposed rule, go to the Postal Service’s proposed rule on the Federal Register site. The USPS needs to hear from everyone affected — the fact that it even published this shows it doesn’t understand how its postage-paying clients are using mail to market in today’s environment. Join Quad as we help the USPS fully appreciate what the results of their proposal would be.

Dear General Brennan:

As representatives of customers of all Postal Service products, we are writing to share our common concern about the Postal Service’s insistence on continued solicitation of comments for its proposed changes to Marketing Mail. Many of our individual associations have shared their concerns already, and we appreciate the recent Industry Alert which provided some clarity and an assurance that any changes would be delayed until at least 2020. While that Alert relieved some concern, it inadvertently created a new one; some customers are now starting to consider 2020 as a milestone by which they need to be prepared to find an alternative to Marketing Mail. Moreover, mailers who use other products have begun to worry about a “slippery slope” effect, and a similar proposal down the road that would adversely impact a number of items, such as credit cards in First-Class Mail and samples in Periodicals.

Marketing Mail should be considered a bright spot. Service has been improving, volumes have stabilized and with the advent of midterm elections may actually rebound somewhat. With continued strength in the economy, Marketing Mail could help to bolster USPS finances in the face of expected declines in First-Class Mail. Unfortunately, the specter of major structural changes at some point in the not-too-distant future introduces unwelcome instability in an otherwise favorable climate. We share your concern for the future of the postal system and stand ready to work with the Postal Service to collaborate on any changes that will strengthen that future. 

We also have a concern about the process by which this proposal emerged: there was little to no discussion with the industry before the Notice was published. With improved communications and the increasingly effective Mailers Technical Advisory Committee consultation system over the years, we thought this kind of preemptive publication was a thing of the past. We understand that an advanced notice only seeks to gather comment on a potential proposal. But in this case, a very serious change bypassed those who would be most affected, and an opportunity for valuable collaboration and input was squandered. 

Thus, we encourage the Service to take another swing at this one. While a withdrawal of the open Federal Register Notice may seem like a retreat or a defeat, it would actually signal confidence in the continued strength of Marketing Mail which is vital to the future of the industry. As always, we look forward to opportunities to work with you on this and other issues of importance to the mailing industry.

With highest regard from the undersigned,

Cc:

Steve Monteith, VP Marketing
Jacqueline Krage Strako, Chief Customer and Marketing Officer (A)
Thomas Marshall, Chief Counsel and Executive Vice President

Stephen Kearney, Executive Director, Alliance of Nonprofit Mailers
Michael Plunkett, President & CEO, Association for Postal Commerce (PostCom)
Christopher Oswald, SVP, Government Relations, ANA – Association of National Advertisers
Rafe Morrissey, Vice-President, Postal Affairs, Greeting Card Association
Leo Raymond, National Association of Advertising Distributors
Bob Galaher​, Executive Director, National Association of Presort Mailers
Arthur B. Sackler, Executive Director, National Postal Policy Council
Pierce Myers, Executve Vice President & Counsel, Parcel Shippers Association
Wanda Senne, Industry Co-chair, Mailers Technical Advisory Committee
Donna Harman, President & CEO, American Forest & Paper Association
James Cregan, Executive Vice President, MPA, Association of Magazine Media
Maynard Benjamin, Envelope Manufacturers Association
David J. Steinhardt, President Emeritus, Idealliance
Mury Salls, Association Executive, Major Mailer Association
Tonda Rush, General Counsel, National Newspapers Association
Paul Boyle, Senior Vice President / Public Policy, News Media Alliance
Donna E. Hanbery, Executive Director, Saturation Mailers Coalition
Steven J. Krejcik, President, Association for Mail Electronic Enhancement