This CSR discusses whether a questionnaire may be considered matter related exclusively to a subscription or a request for a Periodicals publication.
Domestic Mail Manual (DMM) 207.4.12 provides, in part, that 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 126.96.36.199 provides, in part, that the only enclosures permitted in Periodicals publications without payment of separate postage are receipts and orders for subscriptions, forms for providing address correction information, and incidental First-Class Mail attachments or enclosures. (See DMM 188.8.131.52 for enclosures that are permissible with the payment of separate postage.) Printed matter containing information related exclusively to a receipt or an order for a subscription may be included as part of the receipt or order for a subscription if it does not advertise, promote or offer for sale other products or services, and if it is for the Periodicals publication with which it is mailed. Copies of publications authorized requester mailing privileges may also contain forms for requesting the publications.
Subscribers can be considered to be requesters to Periodicals requester publications. Under the above regulation, printed matter containing information related exclusively to a receipt or a form used for requesting a requester publication may be included as a part of the receipt or request form if it is for the Periodicals publication with which it is mailed. In other words, the provisions of DMM 184.108.40.206b will apply for the purpose of determining what information can be added to a form used for requesting a Periodicals requester publication.
When a Periodicals publication is measured for advertising content, a publisher's advertising must be included as prescribed in DMM 207.4.12. However, receipts and orders for subscriptions (and requester forms), which are "permissible enclosures" should not be counted as either advertising or nonadvertising matter. Postage for such enclosures is based solely on their weight.
A questionnaire (which is a part of a receipt or an order for a subscription or a form used for requesting a requester publication) that is designed exclusively to enable the publisher to decide whether a potential subscriber or requester should receive the Periodicals publication is considered to be matter related exclusively to a receipt or an order for a subscription (or a request) and may be included as a part of the receipt or order for a subscription (or request form). However, the questionnaire portion may, based on its content, be considered to be the publisher's advertising matter. Questionnaires which contain extraneous matter that is unrelated to subscriptions and requests, such as those which request existing or potential subscribers or requesters to rate products, would not be permissible loose enclosures under DMM 220.127.116.11.
It is permissible under the provisions of DMM 18.104.22.168 and 22.214.171.124 to add the above types of information to the envelopes and wrappers in which Periodicals publications are mailed, and to
protective covers. It is also permissible under the provisions of DMM 126.96.36.199 to add such information to the reverse side of a label carrier (the side that does not bear the address).
In summation, printed matter (including questionnaires) that is related exclusively to the ordering of a subscription to a Periodicals publication or which is devoted solely to requests for requester publications may be included as part of an order form.