Customer Support Ruling

Donation Solicitation/Previous Donation Receipt
June 2005

PS-322 (233.2)

This Customer Support Ruling discusses whether “personal information” in the mailpiece of an organization authorized to mail at the Nonprofit Standard Mail rates causes the piece to be ineligible for Standard Mail rates.

An organization that is authorized to mail at the Nonprofit Standard Mail rates submitted a mailpiece that contains a field that is completed by computer to show the total amount of donations for the previous year with instructions to “keep this notice as a receipt for tax purposes”, as well as a request to “consider making a donation meeting or exceeding the amount contributed last year.”

Domestic Mail Manual (DMM) 233.2.3* provides that mailpieces containing personal information must be entered at First-Class Mail rates unless they are eligible for Standard Mail or Package Services rates under the respective provisions. DMM 243.2.2* 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.

A review of the mailpiece indicates that it contains personal information; i.e. the amount of the previous year’s donation. In addition, the first two conditions in section 243.2.2 are met; i.e. the request to consider making a donation meeting or exceeding the amount contributed last year is an explicit solicitation for a donation and the personal information (the previous year’s donation) is directly related to that solicitation.  However, the mailpiece does not meet the third condition in 243.2.2 since it includes instructions to the addressee to “keep this notice as a receipt for tax purposes.” Thus, the personal information (the amount of the previous year’s donation) is not included in the mailpiece exclusively to support the advertising or solicitation in the mailpiece, but has a “dual use” as both a tax receipt and support for a current request for contributions. Therefore, the mailpiece is subject to the First-Class rates of postage.

*See also DMM 333.2, 433.2, 343.2, and 443.2.

(Signed)
Sherry Suggs
Manager
Mailing Standards
United States Postal Service
Washington DC 20260-3436