20% non-advertising content difference necessary to create a separate publication
April 12, 2017
By Max Heath
Postal hotline Q & A
How much editorial content difference is required to keep separate Periodicals permits?
The National Newspaper Association is often called upon to help members deal with problems resulting from the need, especially in difficult economic times, to keep different Periodicals publications operating in compliance with Domestic Mail Manual rules.
Newspaper clusters serving contiguous suburban areas with multiple titles often sell advertising in many of those titles as a “group buy.” Then the question becomes whether shared news has value in more than one title, which often it does.
And sometimes, there is a creep toward too much identical content because of decreasing budget for editorial employees. This can even happen in rural counties where two papers in nearby towns are brought under the same ownership.
The answer of having 20 percent difference in non-advertising content lies in Customer Support Ruling PS-141, which interprets DMM 207.6 Periodicals Qualification standards. I am quoting it below in full:
“This CSR discusses the eligibility of mailing similar copies of newspapers or other publications under different permits.
“Only one permit for Periodicals mailing privileges may be authorized for a newspaper or other type of periodical publication.
“An examination of copies of concurrent issues of two Periodicals newspapers disclosed that they are identical except for the titles and identification statements. It appears that the publisher is publishing the same newspaper under two titles and has a separate Periodicals authorization for each title. Since under the present manner of preparation there is in fact only one newspaper, Periodicals mailing privileges may be authorized only for one newspaper.
“If the publisher can prepare his two newspapers in such a manner that he can demonstrate by customary journalistic standards that the newspapers are different, each newspaper can be considered to be independent for postal purposes. This means that if the non-advertising portion in one newspaper differs by at least 20 percent from the non-advertising portion in the other newspaper, they will be considered as being separate and independent newspapers.
“It should be noted that this percentage is an interpretative aid to help us make this determination on a consistent and fair basis. One method of determining whether the non-advertising portions of two publications differ by at least 20 percent is as follows:
1. “Measure the non-advertising content of each publication.
2. “Compare the non-advertising matter in the publications and, in the publication with the greater number of column inches of non-advertising matter, (publication ‘A’) mark all such matter that is different from the non-advertising contents of the other publication (Publication ‘B’).
3. “Measure the number of column inches of non-advertising matter in publication ‘A’ that was marked as different.
4. “Divide the figure from (step 3) by the total number of column inches of non-advertising matter in publication ‘A.’
5. “Multiply the result by 100 to express the answer as a percentage.”
Can I mail the newspaper at Standard Mail (now renamed Marketing Mail) prices instead without changing content to comply with the 20 percent rule of thumb for differentiating separate Periodicals titles?
The short answer is no. CSR PS-186 addresses this. Interpreting DMM 22.214.171.124, it makes clear that incomplete copies of a newspaper may be mailed at Standard Mail prices. Complete copies can be mailed at Periodicals prices. Therefore, complete copies may not be mailed at Standard prices. The key language:
“Publishers may choose to mail any or all copies of their Periodicals publications at Express Mail, Priority Mail, or First Class Mail prices. However, they may mail only the types of copies specifically allowed by postal standards at the U.S. Postal Service Marketing Mail or Package Services prices. They may not, for example, arbitrarily choose to mail subscriber copies at the USPS Marketing Mail or Package Services prices, even though postage computed at those prices may be lower than postage at Periodicals prices.”
Can I use a section of the newspaper as a “shopper” mailed Standard Mail to non-subscribers of the newspaper to provide total market coverage of households for advertising and ad supplement purposes?
Yes. This practice was started by the late Bill Branen and Publisher Larry Tobin at the Tomahawk (WI) Leader. Branen, a legendary Burlington, WI, publisher, was a postal pioneer in developing forward-thinking practices, and training others through seminars. Often called “The Tomahawk Plan,” it uses the rule cited in an earlier question allowing incomplete portions of a Periodical to be mailed at Standard (now Marketing Mail) prices.
Newspapers stack a B section of the newspaper with ROP advertisers that want to pay higher advertising rates to reach every household in the market. Then, after the newspaper pressrun is complete, an additional pressrun of the section without the nameplate of the newspaper, plus a permit indicia in the upper right, is completed for non-subscriber households. Classifieds are sometimes included at an upcharge, like ROP. That section, sometimes renamed something like “Leader/Plus” or something entirely different atop the former section front, is then mailed using a labeling list of nonsubscriber addresses. © Max Heath 2017
MAX HEATH, NNA postal chair, is a consultant for NNA members and Landmark Community Newspapers. He is sponsored by Interlink Software. Email email@example.com.