Does the USPS' 24-page rule for request circulation still make sense?

Is your magazine less than 24 pages?

 

Ever since the USPS gave requested (controlled circulation) publications postal rate status equivalent to that of paid publications, a 24-page minimum rule (707.6.4) has been imposed on requesters that is not imposed on their paid counterparts.

 

The rule was put in, and has been kept there, based on the idea that the Periodicals class would be somehow cheapened if, for example, four pages--one of which was editorial--could be mailed at the same rate as, and with the same "status" as, other periodicals with far greater ad and edit page counts.

 

With the decline in ad pages, there are some requester publications that have had difficulty in the past few months reaching 24 pages with paid ads and quality editorial, but they are forced to spend scarce dollars producing and mailing additional pages to maintain the Periodicals rates.

 

Would you like to see the USPS rescind the 24-page rule? 

 

What do you think about changing the rule? Should it be maintained? Eliminated? Changed to some lower number of pages but not eliminated altogether?

 

I look forward to reading your comments.

Comments

[David Straus]

One of the comments above hypothesizes an "additional 30% in postage fees" when complying with the 24 page rule, presumably comparing postage for 24 pages to postage for 18 or so pages. But the postage differential is not nearly that great. More than half of the postage cost is based on pieces, not pounds, so a good deal of the postage expense will not vary with the number of pages. In addition, in some cases a reduction in pages will cause the printer to stop co-mailing due to the decreased thickness and weight, so any postage differential could be further reduced or even eliminated. I suppose that paper costs are directly proportional to pages, but becasue of make ready and other costs, printing costs will not be. I'm not intending to take a position on a page reduction but only to clarify the facts.

[Gloria Adams]

I believe there should be a percentage of issues that need to meet the 24 page rule - i.e. half of the issues in a year must contain a minimum of 24 pages. Or, one could even do an average over the year of 24 pages. That way publishers have the option with smaller issues of being able to print and mail but still maintain some of the integrity of periodicals rate.

[mike popalardo]

The ad/edit ratio applies, the rule seems redundant or a bit like belt and suspenders. Magazine Publishers are not going to consistently mail issues that they lose money on.

[Emelda Barea]

I guess there has to be some type of a rule to keep the integrity of the periodical pubs be it 24 or 16 or some other # of pages.

It really does not matter much because the ad/ratio % will still apply.

But by lowering the # to may be 16 pages will allow small publishers to survive during these tough economic times

[Dale L. Griffiths]

The USPS 24-page rule was applied for good reason. Maybe it needs to be reviewed but to eliminate it or drastically reduce the requirements presents an unfair competitive advantage against publishers of traditional periodicals. Relax, reduce, or eliminate the rule and you open the periodicals rate to "ad sheets" that have no resemblance to a periodical--and that sell at below-market ad rates. That is a significant threat to the already weakened vitality of the magazine publishing industry.

[Jim Cowart]

I understand why the post office might have this rule, but as long as publishers meet the other ad/editorial ratio rules established by the post office, in this economic climate, the post office should be more flexible with the page count.

If they continue to require this 24-page rule, it will likely cause some publishers to choose to cease their publication before they pay the post office an additional 30% in postage fees. Yes, the post office likely wants to receive the increased revenue that it would get from charging for bulk rate status, but is it willing to risk getting no revenue if publishers choose to not mail their publication due to the increased postage costs? It seems likely that more times than not, this decrease in volume will only add additional revenue shortages to the post office.

Publishers typically experience several months of light advertising each year. Maybe a compromise could be reached where the post office only required publishers to meet the 24-page rule 50% or more of the time? This would allow publishers to lessen QTYs in months where advertising was low and increase/maintain size to be greater than 24 pages in months where advertising was higher.

[Antoinette De La Flor]

Based on the current advertising decline this rule should be eliminated, and if not, at least reduced to 16 pages, in order to give small publications a fair chance to survive during this economic crisis.