Are you taking full advantage of your sampling rights?

Posted May 16, 2014

By Max Heath, Chairman, National Newspaper Association Postal Committee, KPA Past President

The value of sending sample copies to nonsubscribers/nonrequesters using your 10 percent in-county “sampling” entitlement is too-often overlooked as a growth tactic for both circulation and advertising. The nonsubscriber rules in the Domestic Mail Manual are there to allow you to promote your newspaper to nonsubscribers and increase your mail delivery.

There are two key principles to remember in the postal rules:

1) If you want to use the preferred within-county rate, you must observe the 10 percent sampling rule explained below; and,

2) if you are willing to pay the “outside-county” rate for sampling over your 10 percent allowance, you can send many more copies for free so long as you abide by the 50 percent plus 1 rule, also explained below.

If you do so much sampling that your newspaper is not mailed primarily to a paid (or requested for requester newspapers) list, you can lose your Periodicals permit.

Print subscriptions now compete with their own websites, paid or free, and other free news sites locally, regionally, and even nationally.

Newspapers have to work harder to grow paid subscriptions.

Some papers have had success sampling a route or two at a time for two to four issues.

Others choose to sample an entire ZIP code or the entire county at one time.

But either way, sampling addressed copies to 90 percent of the active residential addresses per route, or 75 percent of total addresses (includes businesses), on in-county routes earns you a relatively low 6.5-cent Saturation piece price (4 oz. paper entered at DU— Delivery Office). That compares to a 9.8-cent piece price for Basic (6-124 pieces per route) in-county, saving you one-third of the per-copy price.

Include a good offer to subscribe or renew in each sample copy. For those worried about offending current subscribers, make the offer two-tiered, with a higher discount level for new subscribers, and another lower one for renewals. A flyer with coupon works better than ROP ads. But use a coupon, regardless.

Requesters cannot offer an incentive, but can offer up to 3 years subscription for a request.

The more in-county subscriber/requester copies you can build and retain, the greater your sampling privilege is to sample at incounty rates in the future, without paying outside- county rates for nonsubscriber/nonrequester copies sent above the 10 percent rule.

Review of postal sampling rules Domestic Mail Manual 707.7.9.3 specifies

that in-county eligible newspapers can mail 10 percent of the in-county subscriber copies in a calendar year to nonsubscribers using the lower in-county rates. To estimate your entitlement,

add the subscriber copies column, lines A1/A2 of your 3541 Postage Statement.

Multiply times the number of issues in a year, and take 10 percent of that.

For example, a weekly with 3,500 average in-county mail subscriber copies can send 18,200 copies to nonsubscribers at in-county rates (3,500 x 52 = 182,000 x .10 = 18,200) in a year. Double that for a twice-weekly paper. A 5-day mailed daily earns 91,000 non-subscriber copies at in-county rates under that formula.

Some vendors provide CDS (Computerized Delivery Sequence) files giving all addresses in a ZIP, for use by those mailing to non-subscribers only with specific addresses.

Alternatively, you may use the “simplified address” of “Residential Customer” (DMM 602.3.2.1.b) when sampling either rural or city routes. But you must mail to 100 percent of either active or residential addresses.

Newspapers are not required to duplicate subscriber copies when using simplifiedaddress saturation mail. Confusion may arise from a sentence in DMM 707.7.2 that states “If a subscriber or requester receives a simplified address copy in addition to the subscriber or requester copy, the additional copy is considered a nonsubscriber or nonrequester copy.”

Also, when sampling infrequently, a single issue can mail more nonsubscriber/nonrequester copies than subscriber copies. “…the one time or occasional circulation of nonsubscriber

copies in excess of the number of subscriber copies cannot be the sole basis for a determination of noncompliance with the standards” regarding compliance with the 50 percent paid rule. (See Customer Support Ruling PS-228, third graph, at Postal Explorer website.)

Simplified address copies do not technically count as subscriber copies, though it would be just for those copies that would actually be subscriber copies to do so.

But remember that a newspaper cannot consistently mail more than 50 percent of its total distribution free.

Samples above 10% pay regular rates

Those needing to sample above the 10 percent in-county rate ceiling pay regular (outside- county) carrier-route prices of 14.6 cents for Saturation piece price on Line C35 of the 3541, plus 14.6 cents per advertising pound and 12.3 cents non-advertising pound at DDU lines B1 and B14 when entered at DUs (delivery offices). The copies should be co-mingled as part of the regular issue, and not a separate mailing.

USPS provides a Periodicals Nonsubscriber Percentage Calculator at Postal Explorer ( Click on Postal Links in the upper left of the blue vertical toolbar, then scroll to the last item in that section for the Excel spreadsheet. This can help a newspaper track its entitlement and compliance across a year’s time.

Increase advertising when you sample

You can also increase ad revenue when sampling your entire market at once. Your market may be an entire county, or the primary ZIPs inside the county that you serve. With advertising slow in this weak economy, you need to provide your advertisers and potential advertisers a reason to spend their scarce dollars with you. What better way than to provide them total-market coverage in a paid news product?

Some papers have known this for years, and built both circulation and advertising with monthly sampling, often tied to the issue nearest the start of a new month when government paychecks are in the hands of residents on fixed incomes. Although sampling this often usually results in several issues mailed at outside- county carrier-route prices, it can still pay off if revenue growth is strong enough.

A newspaper group that has made sampling for revenue growth a primary goal has seen papers increase more than 100 percent in per issue ad dollars, with many papers up 50 percent- 70 percent. An average for one month of those sampling averaged over 30 percent

increase. Variables include the depth of economic difficulty locally, the commitment and execution by sales reps, and the date picked, such as seasonal or local retail occasions.

Some newspapers bump ad rates higher, although others offer local merchants the opportunity to reach every household at existing rates, which grows revenue and loyalty.

Some with shoppers allow the sample to replace an issue of the shopper, saving Standard Mail postage as well.

© Max Heath 2014

Max Heath, NNA postal chair and KPA Past President, is a postal consultant for Athlon Media, publisher of Athlon Sports magazine, American Profile, Relish, and Spry newspaper supplements, and Landmark Community Newspapers, LLC.