Advertising for Services
In this Customer Support Ruling
determination will be made as to whether certain “personal”
information present in the mailpiece is part of an “explicit”
advertisement where all of the personal information is “directly
related” to the advertisement and the “exclusive” purpose for
including the personal information is in support of the
The subject of this
ruling is the classification of a solicitation by a firm that
assists notary publics when applying to renew their appointments.
The mailpiece contains a printed letter advising the addressee
his/her Notary Commission expires soon, and urging the addressee to
use the services of the firm to renew his/her commission. Included
as an integral part of the mailpiece is a State Application for a
Commission as a Notary Public. The printed letter contains the name
and address of the notary public (the addressee) and a state
commission number (similar to an account number that merely
identifies the addressee), neither of which is generally considered
to be “personal information” for mail classification purposes. There
is no other personal information in the letter.
application is partially completed and includes personal
information; i.e. the date of birth of the addressee, the expiration
date of his/her commission, and the state and county in which the
commission is held. The partial completion of the application makes
it easier for the addressee to utilize the sender’s services; that
is, the sender merely needs to verify the accuracy of the
information rather than complete the form on his/her own.
provisions of Domestic Mail Manual (DMM) 333.2.3* material
containing personal information is subject to First-Class or Express
Mail postage. Personal information is any information specific to
the addressee. DMM 343.2.2* 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.
Examination of the mailpiece
demonstrates that it contains personal information; i.e. the
information on the partially completed application form.
Accordingly, the piece must be examined for compliance with the
three-part test in DMM 343.2.2.
Review discloses that the piece contains
an explicit advertisement for a service; i.e., the services of the
sender available for a fee to renew the addressee’s commission as a
notary public. The next step in the process is to consider whether
all of the personal information is related directly to the
advertising. The personal information included on the application
form is required to be furnished on the State’s application in order
to apply for re-appointment as a notary public. As explained in the
printed letter accompanying the form, the information is included to
persuade the addressee of the convenience of using the sender’s
service. Accordingly, all of the personal information in this case
is directly related to the advertising in the mailpiece.
The final step is to consider whether
there was any purpose for inclusion of the personal information
other than to support the advertising. Nothing in the mailpiece
indicates the personal information is included for any purpose other
than to convince the addressee to utilize the sender’s services to
apply for renewal of his or her appointment as a notary. Therefore,
it is concluded that all of the information in the mailpiece appears
to have been provided solely for the purpose of enhancing the
Based on the above, the mailing was
determined to be eligible for the Standard Mail rates.
*See also DMM
133.3, 233.2, 433.2, 243.2, and 443.2.
United States Postal Service
Washington DC 20260-3436