Graphic Media Alliance

In Order No. 8937, issued on the afternoon of May 25, the PRC rejected a Postal Service proposal, filed December 20, 2024, (Docket MC2025-948) to eliminate Bound Printed Matter as a market-dominant product.  In the same order, the PRC approved a concurrent USPS proposal (Docket MC2025-958) to increase the weight limit for Marketing Mail.

In the 2006 Postal Accountability and Enhancement Act that, among other things, separated postal classifications into market-dominant and competitive products, Bound Printed Matter was listed as among the package services that were market-dominant.  The law allowed the commission to move a product from one list to another under specific criteria.

This wasn’t the first time that the Postal Service sought to change BPM.  In Docket MC2021-78, filed March 26, 2021, the agency proposed to move Bound Printed Matter parcels to the competitive product list as a subcategory of Parcel Select.

The Postal Service’s proposal last December again sought to move BPM parcels and flats to the competitive product list, but it sought to mitigate the impact on affected mailers by proposing to adjust Marketing Mail weight limits in a concurrent filing.  The USPS presumably concluded that current senders of BPM parcels and flats would find prices for either competitive product BPM or amended Marketing Mail – and the related classification standards for each – to be suitable alternatives.

However, the commission didn’t quite see it that way.  In its decision, the PRC observed:

“As noted by multiple commenters, BPM Flats and BPM Parcels are not actually duplicate products of Media Mail/Library Mail and USPS Marketing Mail, even with the proposed increase to the weight limit of the latter.  USPS Marketing Mail is limited to advertising and promotional materials, while Media/Library Mail does not permit drop-shipping and has a more-restrictive content limitation than BPM Flats and BPM Parcels.

“A current Bound Printed Matter customer that dropships fulfillment mail pieces cannot do so either with USPS Marketing Mail (as fulfillment does not qualify as advertising and promotional materials) or with Media Mail/Library Mail (which lacks a drop-shipping option).  Such a customer’s only choice would be to enter their mail pieces as end-to-end Media Mail/Library Mail (paying that product’s higher price, not receiving a dropship discount, and sacrificing the shorter service standards available with drop-shipping) or else to ship their mail pieces using a Competitive product.

“Indeed, the Postal Service estimates 87 percent of fulfillment BPM Parcels volume will migrate not to the ostensibly ‘duplicate’ Market Dominant products, but to Competitive products, seriously undermining the Postal Service’s claim that BPM Flats and BPM Parcels are redundant.”

By comparison, the proposal to increase the maximum weight for Marketing Mail received little attention or opposition, with two commenters calling it “uncontroversial.”  The sum of the PRC’s analysis of the proposal was:

“The Commission finds that the proposed change should have only a positive impact on users of USPS Marketing Mail by increasing opportunity and should have only a negligible impact on Postal Service competitors.  The Commission also finds that the proposed increase to the maximum weight limit for USPS Marketing Mail is in accordance with the policies and applicable criteria of chapter 36 of Title 39 of the United States Code.”

Accordingly, in its conclusion, the commission stated, “… the Postal Service may implement the proposed increase to the maximum weight limit for USPS Marketing Mail.  The Postal Service shall notify the Commission of the effective date of the classification changes.”