USPS Management Optimistic About Marketing Mail Merchandise Solution

March 5, 2019

We received briefings from the Postmaster General and her leadership team at two meetings last week—mailer associations and MTAC.   Six months after the infamous August 23, 2018 Federal Register Notice that contemplated rule changes to ban all merchandise from Marketing Mail, postal management seems amenable to accept the recommendations of the MTAC Task team 27 that has been working for two months.

The gist of the recommendations is that “promotional” items such as front- and back-end premiums, as well as all paper-based items, will be allowed to continue in Marketing Mail, whether commercial or nonprofit.  The kind of merchandise USPS wants to move to other classes is what they term “fulfillment.”

The Postal Service is now making an important distinction between mail that fulfills an order by a customer buying the goods, and “promotional” or “non-fulfillment” Marketing Mail that contains merchandise.  USPS cited the existing rules for Marketing Mail parcels that do not allow “fulfillment,” and said it is thinking of extending that principle to MM letters and flats.

A problem with the exiting restriction is that “fulfillment” is not adequately defined.  Currently, it is a very brief parenthetical in the Domestic Mail Manual Section 243.3.2.2:

All USPS Marketing Mail Marketing parcels (regular and nonprofit) must bear an alternate addressing format and cannot be used for “fulfillment purposes” (i.e. the sending of items specifically purchased or requested by the customer of a mailer).

Promotional premiums can be “requested” by customers when they donate, join, subscribe, or sign up for an event.   Sometimes organizations and businesses offer choices of more than one premium, and the customer requests the one they want.

So, the task team recommended, and we agree, that the Postal Service needs to further refine and clarify the definition of “fulfillment” if it intends to make that term the lynchpin of its rules allowing/not allowing merchandise in MM.

In the meantime, senior USPS officials expressed their intention to issue an “Industry Alert” in two to three weeks, clarifying the focus of the August 23 Federal Register Notice.  They provided two documents summarizing where they are, and we posted them here.

Any comments can be sent to Stephen Kearney at steve@nonprofitmailers.org, or directly to the USPS via Judy A. de Torok, Manager, Industry Engagement and Outreach, at judy.a.detorok@usps.gov, no later than Friday, March 8, 2019.