Customer Support Ruling

Verification of Circulation
Updated October 1996

PS-248 (707.8)

This Customer Support Ruling discusses a procedure to assist in the verification of records for publications with large circulations.

A publisher of nine Periodicals publications filed applications to reenter them from the requester to the general publications category.  This meant that the postmaster at the post office where original Periodicals mailing privileges were authorized would be required to perform a verification of the circulation records to ascertain whether the publications were being distributed under the circulation standard prescribed for general publications.  When such verifications are performed, publishers generally provide a galley (mailing list) to the postal auditor who then requests, by a random sampling procedure, to see records which will substantiate that the persons claimed as subscribers are such in fact.

In this case, since there was a total of almost six million subscribers to the nine publications, the publisher was reluctant (because of the expense) to print a list of all of the subscribers and requested that he be allowed to substantiate his claimed paid circulation without providing that list.

Publishers of Periodicals publications which have large circulations may submit to the postal auditor, a report that lists all of the ZIP Code areas serviced by the publication along with an adjacent count showing the number of copies distributed to each of those areas.  The total number of ZIP Codes should also be shown.  This type of a report will enable the postal auditor to adequately determine the volume of copies distributed.  The postal auditor should randomly select a sample of ZIP Codes and the publisher should be requested to print a galley of the names for those ZIP Codes.  This procedure will result in a smaller number of names being printed by the publisher, but should be sufficiently representative of the list of subscribers to allow the postal auditor to pick names at random in the usual manner for the purpose of ascertaining whether the publication is being distributed under the circulation standard prescribed for general publications. 

 (Signed)
Anita J. Bizzotto
Manager
Mailing Standards
United States Postal Service
Washington DC 20260-3436