Requester Periodicals gain easier options to get and keep requesters on their lists
July 31, 2012
75% ad rule amended
to help publishers January 2013
By Max Heath
The National Newspaper Association has obtained several changes in the rules affecting Requester Periodicals status, working through the Periodicals Advisory Group. And final details around some of those previously announced are now available. All are improvements. The availability of in-county prices to Requester publications under the 2006 Postal Reform Act has spurred interest in converting to Periodicals for free newspapers, sometimes attracting new mail volume.
This joint industry/postal task force is comprised of magazine publishers, their printers, postal specialists from the Product Classification department (formerly Mailing Standards) of USPS headquarters and the Pricing and Classification Service Center in New York City. The PAG has been helpful to NNA, if painstakingly slow at times, because all decisions are reached by group consensus.
NNA is fortunate to have had a seat at the table since its creation in the mid-1990s. We are the only association representing unbound Periodicals on the group. As your representative, we worked for more than four years to get the recently finalized approval for paid or Requester electronic subscriptions (and paid/Requester website access) to be counted on the annual statement of ownership, PS Form 3526. (See this column in June, 2012 issue or at www.nnaweb.org.)
ELECTRONIC & FAXED REQUESTS
The biggest breakthrough, perhaps, is the addition of new request options in addition to original signed cards or forms, which require in-person solicitation or mail-back by the individual requester. Jeanne Straus, publisher of nine Requester titles in New York, New Jersey and Pennsylvania, was key in helping NNA gain the change, appearing twice over two years before the PAG meeting in New York.
A revised Customer Support Ruling, PS-054, was issued last year, but was fleshed out at a June meeting this year. The current version can be seen at http://pe.usps.gov/text/CSR/PS-054.htm. Point one clarifies that signed and dated request forms can be faxed.
Point two allowing electronic requests, is the one opening up reader-friendly avenues such as the publication’s website, where a properly-created matrix supplying all necessary information required by USPS can be added. The June 14 PAG meeting clarified that electronic requests must include (with my remarks in parentheses/italics):
1. Title of the publication. If multiple titles are offered they must be produced by a single publisher. If the title is printed in full on the subscription offer, abbreviations in requester records are acceptable. (This last sentence means that when the Requester title sells subscriptions—say, outside its primary market area—the title’s complete name must appear, with abbreviations allowed for the larger Requester portion.)
2. Requester’s name.
3. Terms—length of the subscription (up to three years, for which most publications will want to ask).
4. Physical address (even if a post office box is the mail address).
5. E-mail address (which is considered an electronic “signature”).
6. Date of the request.
7. A copy of the offer (necessary as no premium of value can be offered to induce a requester).
NNA suggests—in concert with Product Classification—that Requester Periodicals print and keep the records generated by electronic methods for easy access to proof, should they be required. USPS is not set up to audit electronic files, which can vary in format and storage.
75 percent ADVERTISING LIMIT HAS BEEN relaxed EFFECTIVE JAN. 1, 2013 FOR REQUESTERS
Requester Periodicals have long been required to have at least 25 percent non-advertising material in all issues. Said another way, no issue of a Requester Periodical could exceed 75 percent, though occasional issues could be mailed at higher Standard Mail rates if necessary rather than bump up editorial pages to comply when supplement volume was high.
NNA asked that Requesters be allowed to exceed 75 percent advertising matter in 25 percent of their issues in a 12-month period. After two PAG meetings more than a year apart (again with the help of Straus) all parties finally agreed to grant this rule change. Because General (paid) Periodicals rules are allowed to exceed 75 percent advertising in half their issues, we argued that a number at the mid-point between the two current extremes was appropriate.
NNA asked in March that this be effective Oct. 1, 2012, in what we thought was generous to USPS to get their systems fixed. Unfortunately, after much back-and-forth, programming contractors and USPS management decided it could not be programmed in time for the deadline.
Despite our efforts to reverse the decision, it appears we must accept the delay. In this weak economy with ROP advertising harder to come by, we understand that heavy insert loads in the fall mailing season may work a hardship on some publishers. But without a PostalOne! upgrade, Requester Periodicals cannot take advantage of the new rule. So it’s not effective until Jan. 1, 2013.
OTHER IMPORTANT REQUESTER RULES
As pointed out above, electronically-fulfilled Requester newspapers and website access can be counted on the 3526 Statement of Ownership this Oct. 1 for the postal fiscal year from Oct. 1, 2011, through Sept. 30, 2012. And because fax and electronic methods of requesting the newspaper are now valid, this allows Requester publications avenues to grow a higher percentage of qualification.
That is important because Requester publications must have 50 percent or more requested copies to be eligible for Periodicals status, and getting and keeping that status can be difficult and costly. The bar should be set at 60 percent however, as having fewer than 60 percent in the average column on a statement of ownership can trigger an eligibility audit. The new tools help achieve that.
Also, when electronic requesters are counted on a 3526, and the percentage falls below 60 percent, USPS has said it won’t perform the eligibility audit, but instead require an outside audit firm report. This may inhibit some Requester publications from counting electronic subs, which is merely an option.
In-county prices are available on the requested copies, plus 10 percent nonsubscriber privilege, so a paper with 60 percent requesters can claim in-county prices on 70 percent of the total copies mailed. But on the Statement of Ownership, one must hit 60 percent of total distribution paid, not just mailed copies. So all paid subscriptions sold outside a newspaper’s market, or even paid single sales, can help greatly toward getting and keeping 60 percent Requester status.
Also, signed and dated requests for a quantity of copies (bulk requests) from employers that specify the employees, by name or position in the organization, who are to receive copies of the publication are considered valid requests (PS-054, item 9).
The 24-page minimum rule for Requester publications is still intact, though they can be tabloid or broadsheet pages. Advertising supplements do not count in the pages, though they must be measured in the advertising percentage. © Max Heath 2012
MAX HEATH, NNA Postal chair, is a postal consultant for Publishing Group of America (American Profile, Relish, Spry) and Landmark Community Newspapers LLC. E-mail firstname.lastname@example.org.