Reader Service Cards
Updated October 1996
This Customer Support Ruling 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)
707.4.13.1, 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 707.4.13.1 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 707.3.3.4 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 707.3.3.4 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 the Periodicals rates of
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
Washington DC 20260-3436