New marked copy rules prevent submitting multiple copies if only preprints in editions are different
September 29, 2015
advertising standards, measurement
By Max Heath
A change to Domestic Mail Manual 207.16 effective Sept. 14, 2015, limits the number of marked copies, which must be submitted when there are “multiple editions of a Periodicals publication.” The wording now states that you must submit only “the main or most prominent edition of the issue and must have all other editions available for review upon request.”
This is important to newspapers, which have multiple editions with different preprint combinations indicated by weight, even though the “mainsheet,” or ROP version of the main newspaper, does not change. Some post offices have required multiple marked copies of the main newspaper to accompany each different weight version, even though nothing changed inside that ROP section or sections.
Also, the advertising content may be verified by either the original entry or additional entry office, meaning it does not have to be verified by both.
Although National Newspaper Association’s request to clarify that the marked copy may be submitted the next business day after entry of the mail was not included in this change, we will be working the issue through Business Mail Entry Headquarters. Many reasonable postmasters allow it to come later. NNA has not yet gotten USPS to eliminate the marked copy except on request. The unexpected hurdle was that magazine reps on our Periodicals group reneged on their support. Changes in Periodicals rules are always hard to achieve, because of the sensitivity of compliance with rules intended to keep Standard mail from leaking into the class.
Another reason for resistance is that advertising measurement of newspapers is required to compute higher, zoned pound rates on ad matter by distance outside the county, and allows lower zoned rates for all editorial or nonadvertising matter. With concern that Periodicals are already not covering cost, mailers worry about loosening rules that may cost USPS ad-rate postage money.
Rules concerning ad measurement are shared below, with citations from the U.S. Postal Service Domestic Mail Manual and Customer Support Rulings. Both are available at the Postal Explorer website.
Advertising is defined in DMM 126.96.36.199 as:
(a) “All material for the publication of which a valuable consideration is paid, accepted, or promised, that calls attention to something to get people to buy it, sell it, seek it, or support it.”
(b) “Reading matter or other material for the publication of which an advertising rate is charged.”
(c) News stories run in return for an ad in the same issue must also be counted as advertising (though put more simply here than in DMM.) Therefore, paid obits are counted as paid linage.
(d) “House ads” for newspaper subscriptions, advertising, websites, or businesses owned by the newspaper are also considered paid advertising, whether in display advertising or reading matter.
Public-service announcements “for which no valuable consideration is received by the publisher … which promote programs, activities or services of federal, state or local governments or of nonprofit organizations, or matters generally regarded as in the public interest” are not treated as advertising. (DMM 188.8.131.52)
“The total advertising and nonadvertising portions may be determined by column inches, square inches, pages, or by another recognized unit of measure,” so long as the same unit is used for both portions.
Newspapers cannot be forced to use a certain method.
Most newspapers use column-inch measurement. One must compute the total units of space in the entire publication, as well as the total units of advertising. For instance, a 20-page paper might contain 2,580 total inches of space (6 columns x 21.5 inches x 20 pages = 2,580 inches). If the advertising units measured 1,565 inches, 1,565 divided by 2,580 equals 60.66 percent.
Round advertising percentage to two decimal places, as shown in the previous sentence. Round up numbers five and up; round down four and below. Slash marks through the advertising with a colored marker are adequate. Also, to determine the weight per copy, weigh 10 copies and divide by 10. The weight is expressed in decimal pounds rounded off to four decimal places. (DMM 184.108.40.206)
What about white space?
When using column or square inches, the marginal space should be disregarded. It will take its proportionate share in the percentage of advertising and nonadvertising matter arrived at for the whole issue. CSR PS-12 also states “the border of a page, space between columns, and space between advertisements are neither advertising matter nor matter other than advertising.”
PS-12 also rules that, “In determining the advertising and nonadvertising percentages, one full page of advertising material must equal the same measurement as one full page of news content.” In other words, if one page of all news counts as 129 inches, one page of all advertising will count as 129 inches, even if there are a variety of ad sizes on the page. This is true “regardless of the amount of blank spaces between each advertisement on a page….”
What about page headings?
Headers that accompany ad matter are considered advertising. Likewise, headers accompanying news matter are nonadvertising (CSR PS-143). An advertising index is considered advertising (CSR PS-251)
How do we measure pages with varying columns?
Some papers convert 8-column classified pages to 6-column pages (172 inches to 129 inches) for consistency in measurement. You could follow this practice for tab sections with 4 or 5 columns per page versus broadsheet pages with 6 columns per page.
It is also acceptable to measure inches on tabloid pages as the number of inches times the height (5 columns by 12 inches = 70 inches, rather than half of 129 inches, or 64.5). This measure slightly overstates the ad percentage, however.
How about advertising supplements of various widths?
With the broadsheet or tabloid newspaper open to the two pages that show standard columns, open the supplement with its spine nested inside the broadsheet centerfold. Match the printed width of the ad supplement to the closest number of columns (typically four or five) that it approximates. For example, an eight-page tab whose ad matter measured closest to four columns wide, with 10 vertical inches, would contain 40 inches per page. That would be 320 inches added to the total column inches in the newspaper, and then 320 inches added to the advertising matter.
What is the maximum amount of advertising in an issue?
Regular paid newspapers cannot exceed 75 percent advertising in more than half their issues. A weekly could have 26 issues over 75 percent, but after that nonadvertising matter must be added to any issues that would exceed 75 percent. (DMM 220.127.116.11a) You CAN have 75 percent advertising, just not 75.1 percent and above in more than half the issues.
Requester newspapers historically cannot exceed 75 percent advertising in any issue. However, a rule change said Requester newspapers may exceed 75 percent advertising 25 percent of the time, effective Jan. 27, 2013. This change to 18.104.22.168b was requested by NNA on behalf of its Requester members and is halfway between the current paid and Requester rule. Issues over the limit can be mailed at Standard Mail rates on an occasional basis. (CSR PS-147)
When an issue is prepared in editions, if one edition is more than 75 percent, the entire edition will be considered more than 75 percent. Averaging is not allowed, unfortunately. (CSR PS-241)
What about make-good advertisements?
Ads that are rerun to correct a problem must also be counted as advertising again, even if no money changes hands for the second, corrective run. (This is on advice from the New York Pricing and Classification Service Center.)
What about sealed envelope supplements?
Unbound newspapers may enclose sealed or unsealed envelopes containing sheets of advertising (CSR PS-078) in a ruling obtained in 1997 by NNA. Envelopes can also be in bound Periodicals as result of a rules revision, though they can’t be loose unless the magazine is in a wrapper. © Max Heath 2015
MAX HEATH, NNA Postal Chair, is a postal consultant for AMG | Parade (Parade, American Profile, Relish, Spry Living, TV Times and Athlon Sports magazines) and Landmark Community Newspapers LLC. E-mail firstname.lastname@example.org.