Identification of Nonprofit USPS Marketing Mail Matter

UPDATED January 2017

PS-336 (703.1.5)

This Customer Support Ruling discusses the identification of a nonprofit organization on matter mailed at the Nonprofit USPS Marketing Mail (nonprofit) prices.

Domestic Mail Manual (DMM) 703.1.5 states, in part, that all matter mailed at the nonprofit prices must identify the authorized nonprofit organization.  The name and return address of the authorized organization must appear either on the outside of the mailpiece or in a prominent location on the material being mailed. Pseudonyms or bogus names of persons or organizations may not be used.

In this case study, a mailing by the Conservation Institute, LLC, an organization authorized to mail at the Nonprofit USPS Marketing Mail prices, was questioned as to its eligibility for nonprofit prices because the name in the return address was Conservation Institute rather than Conservation Institute, LLC. The mailing was charged Regular USPS Marketing Mail prices by an acceptance employee suspecting the mailpiece may not be the material of the Conservation Institute, LLC, and in violation of DMM 703.1.5. An appeal was subsequently filed by the organization/mailer.

Domestic Mail Manual (DMM) 703.1.6.1 states, in part, that an organization authorized to mail at the Nonprofit USPS Marketing Mail (nonprofit) prices may mail only its own matter at those prices.

A key question on appeal was to determine whether the material being mailed was that of the authorized nonprofit organization. Upon review of the mailpiece, printing invoice, postage payment evidence, and related supporting documentation, it was determined that the mailpiece was solely that of the Conservation Institute, LLC, despite LLC being omitted from the name in the return address.

In rendering a decision in this case, the Postal Service concluded that the mailing was eligible for nonprofit prices because the matter was solely the material of the authorized nonprofit organization. The decision noted further that omitting “LLC” in the return address did not affect ownership of the mail, raise reasonable cause to suspect an improper cooperative mailing requiring Regular USPS Marketing Mail prices, or violate the intent of the return address provisions of DMM 703.1.5.

It should be noted that the return address requirements for mailings entered at Nonprofit USPS Marketing Mail prices are often relied upon by the Postal Service to identify a mailing that may not be eligible for nonprofit prices.  Omitting “LLC,” “Inc.,” “Corporation,” or “Incorporated,” are generally poor examples of return address identification as an actual indicator of a mailing being ineligible for Nonprofit USPS Marketing Mail prices. Thus, they should not be relied upon by themselves when disallowing an otherwise proper mailing at nonprofit prices.

Further addressing the return address requirements for Nonprofit USPS Marketing Mail, a frequent question is raised as to whether the return address on material to be sent at nonprofit prices must be the organization address shown on the original application, Form 3624, for Nonprofit USPS Marketing Mail prices, and/or shown in official postal records such as PostalOne!.  The answer, so long as the return address to be shown on matter to be sent at nonprofit prices is a legitimate address of the authorized nonprofit organization, it may be used to identify a mailpiece eligible for nonprofit prices. Examples of a legitimate return address include, but are not limited to, the organization address originally shown on Form 3624, if presently valid; a current address entered in the PostalOne! system; or another address belonging to the authorized nonprofit organization, such as an administrative office address that differs from a headquarters address.  Form 6015 is not required to be filed by the authorized nonprofit organization so long as the address shown in the return address on matter to be sent at the Nonprofit USPS Marketing Mail prices is a legitimate return address.

Lizbeth Dobbins
Manager
Product Classification
Headquarters, US Postal Service
Washington, DC  20260-5015