The rules, which are to be fully implemented Oct. 3, will be an especially hard blow to tabloid-sized publications and to skinny magazines, catalogs, and retail flyers. And they might prove to be a hindrance for co-mail operations – which postal officials have touted as an ideal way to reduce both mailers' and Postal Service costs.
The regulations will impose a significant penalty on mail that fails a new flats deflection test, commonly referred to as the droop test, which is supposed to determine whether mail is well suited to the Postal Service’s sortation equipment.
The Postal Service received comments from 35 associations, businesses, and people regarding the proposed regulations – and ignored almost all of them. One exception is that copies in carrier-route bundles delivered to a destination delivery unit (DDU) are exempted.
That change was in response to claims that the regulations would impose a 78% price increase for some In-County Periodicals mailers – and an acknowledgement that the penalties make no sense for copies that are sorted manually. It seems to help mostly small local newspapers. The national dropship networks run by the major printers of magazines and catalogs rarely deliver to DDUs, which is where letter carriers are based.
Among the problems the Postal Service didn’t fix are:
- Carrier-route copies: Except for DDU deliveries, copies in carrier-route bundles are not exempt from the penalties. Even some postal officials had said carrier-route copies would be exempted, because in theory a carrier-route bundle bypasses sortation equipment and goes directly to a letter carrier. The Postal Service did not explain its logic (or illogic) on this point, but it may have to do with copies being handled on Flats Sequencing System machines. So much for the promise that FSS would save mailers money.
- Objective test method: “We are making modifications to improve the objectivity of the testing process,” the Postal Service says in its explanation of the revisions, but it failed to address many concerns. For example, there is no language regarding how a piece is to be handled prior to testing (which can make a huge difference as to how much it droops), when in the process it should be selected for testing (prior to bundling or pulled out of a bundle?), or how many pieces in a mailing should be tested. A cantankerous postal clerk could put a printing plant out of business, while an easygoing one could give the printer a competitive advantage.
- Pre-qualification: Many mailers asked for a way to pre-qualify samples of a mailing rather than producing an entire mailing before discovering that mail pieces fail the droop test. The USPS rejected that, as well as related calls for tolerances of up to half an inch or a certain percentage of failed copies. As a result, although normal magazine-sized pieces can droop up to three inches, mailers would be wise to build in a safety factor and not produce anything likely to droop much more than two inches.
- Co-mail: “We are developing a random sampling procedure to test mailings of nonidentical pieces, including comailed and copalletized mailings,” the USPS explanation says -- but the regulations themselves say nothing about such a process. Cataloguers and publishers that co-mail are concerned that, even if all of their copies meet the standard, they will be penalized for the failings of another co-mail participant’s copy failure. Because printers typically select and presort magazines and catalogs for co-mail before production starts, they will probably exclude anything that has a remote chance of failing the droop test.
- Viagra to the Rescue? Postal Regulations Are Taking the Life Out of Tabloid Magazines explains why the new droop rules are especially problematic for tabloid-sized publications and provides links to videos and explanatory materials about the test.
- Eligibility for Flats Failing Commercial Deflection is the Postal Service's description of the comments and its response, along with the actual language to be added to the Domestic Mail Manual.
- Common Sense Prevails for Flats Deflection - For Awhile discusses why USPS decided this week to delay implementation of the penalties for a few months and describes a Postal Service demonstration of the new test.
- The Cost of Droopy Flats: Joe Schick, Quad/Graphics' postal guru, discusses how difficult it is to predict whether a mail piece will fail the droop test when it's still in the design phase and says the new regulations could mean a 40% postage increase for some mailers.