Customer Support Ruling

Renewal Notices
Updated December 2004

PS-238 (243.2.2)

In this Customer Support Ruling, a determination will be made as to whether a mailpiece containing “personal” information is eligible as Standard Mail.

This ruling concerns the classification of a subscription renewal notice for The Boston Post*.  In addition to the name and address of the customer (the addressee) and account number (neither of which is generally considered to be “personal information” for mail classification purposes), the mailpiece contains personal information in the form of an expiration date of the current subscription.  The notice prominently displays the words “Renewal Notice” and encourages the subscriber to renew before his/her expiration date.

Domestic Mail Manual (DMM) 233.2.3* states that matter that has the character of actual and personal correspondence must be mailed as First-Class Mail or Express Mail.  Postal standards provide that computer-prepared material is not considered to have the character of actual and personal correspondence merely because it contains specific information about: a product or a service being offered for sale or lease; information relating the addressee directly to an advertised product or service being offered for sale or lease; or information such as the amount paid for a previous purchase, pledge, or donation, when associated with a sales promotion or solicitation for donations.

A review of The Boston Post renewal notice indicates that this is advertising material that contains personal information; i.e., the expiration date.  The expiration date is used to relate the addressee directly to an advertised product or service being offered for sale or lease (uninterrupted service of his/her subscription). No other personal information was included in the mailpiece. Therefore, the mailing was determined to be eligible for the Standard Mail rates of postage.

Under the provisions in DMM 233.2.3**, material containing personal information is subject to First-Class or Express Mail postage.  Personal information is any information specific to the addressee.  DMM 243.2.2** provides that personal information may not be included in a Standard Mail mailpiece unless three conditions are met: the mailpiece contains explicit advertising for a product or service for sale or lease or an explicit solicitation for a donation; all of the personal information is directly related to the advertising or solicitation; and the exclusive reason for inclusion of all of the personal information is to support the advertising or solicitation in the mailpiece.

An examination of the mailpiece demonstrates that it contains personal information; i.e. the expiration date.  When examined for compliance with the three-part test in DMM 243.2.2, a determination is made that the piece contains an explicit advertisement for a product; i.e., a subscription to The Boston Post The next step in the process is to consider whether all of the personal information is related directly to the advertising. The expiration date is directly related to the sender’s request that the addressee renew his/her subscription before expiration. Finally, when considering whether there was any purpose for inclusion of the personal information other than to support the advertising, it was determined that nothing in the mailpiece indicates the personal information is included for any purpose other than to convince the addressee to renew his or her subscription. The conclusion is the personal information in the mailpiece is included solely to promote a subscription renewal.

Therefore, the mailing would be considered eligible for the Standard Mail rates.

* This is not the actual title of the publication referred to in the original ruling.

** See also DMM 133.3, 333.2, 433.2, 343.2, and 443.2.

 (Signed)
Sherry Suggs
Manager
Mailing Standards
United States Postal Service
Washington DC 20260-3436