This CSR discusses the classification of a reader service card enclosed in a Periodicals publication.
A reader service card is a card with a series of numbers printed on it that relates to text about products published in copies of a Periodicals requester publication. If a reader wants to receive information pertaining to particular products, he/she circles the appropriate numbers and mails the card. A question has been raised as to whether reader service cards may be inserted loose in bound Periodicals publications and whether the information on such cards constitutes advertising or nonadvertising matter.
Reader service cards must be bound in copies of bound Periodicals publications. They may not be enclosed loose in those copies.
Domestic Mail Manual (DMM) 184.108.40.206, provides that the term "advertising" includes all material for the publication of which a valuable consideration is paid, accepted, or promised; that calls attention to something for the purpose of getting people to buy it, sell it, seek it, or support it.
DMM 220.127.116.11 also sates that if an advertising rate is charged for the publication of reading matter or other material, such material shall be deemed to be "advertising". Articles, items, and notices in the form of reading matter inserted in accordance with a custom or understanding that textual matter is to be inserted for the advertiser or his products in the publication in which a display advertisement appears, are deemed to be "advertising". If a newspaper or periodical advertises its own services or issues, or any other business of the publisher, whether in the form of display advertising or editorial or reading matter, this is deemed to be "advertising".
DMM 18.104.22.168 provides that receipts and orders for subscriptions are permissible enclosures in Periodicals publications and may be inserted loose or bound into each copy. These "permissible enclosures" should not be counted as either advertising or nonadvertising matter. Postage for such enclosures is based solely upon the added weight to the publication resulting from the inclusion of such cards or envelopes.
DMM 22.214.171.124 does not serve as the authority for enclosing loose reader service cards or combination subscription/reader service cards in copies of a bound publication mailed at Periodicals prices.
Reader service cards are not receipts or orders for subscriptions and must normally be counted as advertising matter. They are a vehicle which enables the reader to request information about a product advertised in the publication. If an advertiser purchases advertising space in a Periodicals publication and has grounds or cause to expect that the reader service cards will be inserted for him or his products, or if there is mutual agreement of a private or unannounced kind between the advertiser and publisher that the cards will be inserted in the same issues in which the advertisement appears, the reader service cards would be considered advertising for postal purposes.
If a reader service card has advertising and nonadvertising matter printed thereon, the whole card should be considered to be advertising matter. If a reader service card contains information for ordering a subscription to the Periodicals publication in which it is enclosed, that incidental information would not convert the card to being a subscription order form. The other information on such cards will serve as the determining factor when decisions are made concerning whether all of the information should be considered to be advertising or nonadvertising matter.
Anita J. Bizzotto