3526 form to include e-subs, e-requests for Oct. 1 filing date

July 8, 2014

FINALLY, electronic
subscriptions can be
reported with print readers on one form!
And it took only 6 years

By Max Heath
Postal Tips 

The National Newspaper Association has confirmed that the unified reporting of electronic subscriptions on one form with print subscribers, PS Form 3526, Statement of Ownership, Management and Circulation, is scheduled for release in hard copy and in the PostalOne! postage payment system computers for use in September for the Oct. 1 filing date. Newspapers that use the 3526 to show circulations to advertisers will now have one complete form available.

Although this was the way NNA envisioned it when asking for this rule change back in the last decade, bureaucratic snafus, release schedules, and personnel retirements at the U.S. Postal Service all combined to thwart our efforts even after the approval three years ago.

And, in other news, NNA is working on a new proposal to eliminate the “marked copy” for Periodicals. Instead, publishers would be able to keep their marked copies on file for later audit. This streamlined compliance rule will aid publishers in timely filing of their mailing statements.

The August PostalOne! “Release 38” contains the change that is scheduled for use on Sept. 7, 2014, according to MTAC representative Brad Hill, president of Interlink Software. Other USPS headquarters personnel had given reassurances, but this was the first tangible evidence of that.

This means that the 3526-X form that was required in 2012 and 2013 to report electronic subscriptions as an addendum will now be a third page of the previous 3526 form. The 3526-X will cease to exist.

For paid newspapers, there will be one unified 3526 with print and e-sub reporting. Likewise, for requester periodicals, there will be a unified 3526-R for print and e-requesters. Both hardcopy forms are already posted on Postal Explorer website. Scroll down the left blue toolbar to “Postage Statements,” then “Periodicals forms” and you will see the updated 3526 and 3526-R dated 7-2014.

The new form allows combining the total paid print and electronic copies for both “Issue closest to filing date” and “Average copies for previous 12 months,” achieving NNA’s goal to get recognition for electronically-fulfilled subscriptions or requester copies added for those newspapers for whom the Statement of Ownership is their legal proof of circulation for advertisers, advertising agencies, and public notices.

This change will include accessibility of a single automated online form that can be completed electronically visa PostalOne!. Many NNA members prefer to file the document electronically rather than hardcopy.




The Postal Service is currently finalizing a proposal to eliminate the requirement to submit a marked copy showing advertising content with each issue mailed, and each edition (weight version) of an issue.

The rules change is still under review by various USPS headquarters departments, but the Business Mail Entry managers have given their blessing. If the proposal gets final approval, newspapers would still have to retain marked copies in their own office for one year. Measurement is still necessary to determine advertising percentage for the zoned pound rates for mail outside the county.

Per current standards, a publisher must mail one copy of the issue to their known office of publication. The marked copy has always fulfilled that requirement, so that requirement will also be reviewed.

The Postal Service will retain the right to request a marked copy from a publisher at any time deemed necessary. And a marked copy will still be required at least once a year during the annual postage payment review, which is usually conducted in October in conjunction with the filing of the required Statement of Ownership, Management and Circulation discussed above.

The Postal Service and the mailing industry both agree that the marked copy requirement is archaic and outdated. The risk assessment is considered low. There is also the concern of space required for storage of marked copies. In the massive James Farley post office in New York City, where I attended a meeting of the Periodicals Advisory Group last week, there is a large room dedicated to retention requirements of magazines and newspapers.

The issues discussed in this column are among those worked through the PAG, in which NNA has possessed the only seat representing unbound newspapers since its formation in the mid-90s. The PAG works on issues and ideas by mutual consent of Postal Service representatives from the Pricing and Classification Service Center in lower Manhattan, headquarters representatives of Product Classification, and representatives of the Periodicals industry, including magazines and their printers mostly.

Participation in PAG is just one of the many ways NNA represents community newspapers in postal affairs. There are three industry reps plus NNA Chief Executive Officer Tonda Rush on the Mailers Technical Advisory Committee, which meets quarterly. There are also numerous work groups and task teams that work year-round on issues under MTAC auspices. I am on a Mail Prep work group and a processing Hub group, as is Hill and Rush. Hill serves on a variety of work groups on technology and IMb issues.

Rush has spent many hours for months working with the Flats Strategy group in Washington that affects handling of Periodicals. And, of course, she works countless hours on Capitol Hill on behalf of NNA members as well as representing us all at the Periodicals Regulatory Commission. © Max Heath 2014


Max Heath, NNA postal chair, is a postal consultant for Athlon Media, publisher of Athlon Sports magazine, American Profile, Relish, and Spry newspaper supplements, and Landmark Community Newspapers LLC. Email maxheath@lcni.com.

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