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S900 Special Postal Services
S920 Convenience
S922 Business Reply Mail (BRM)
Summary
S922 describes BRM, describes permit requirements, and fees. It covers the format and application process required of BRM mailpieces, the standards for prebarcoded BRM, and the characteristics of envelopes used with BRM.
1.0 Basic Information
1.1Description
Business reply mail (BRM) service enables a permit holder to receive First-Class Mail and Priority Mail back from customers and pay postage and a per piece fee only for the pieces returned. BRM cards, envelopes, self-mailers, cartons, and labels may be distributed by a BRM permit holder in any quantity for return to any post office in the United States and its territories and possessions, including military post offices overseas. Qualified Business Reply Mail (QBRM) is a subset of BRM available for specific automation-compatible letter-size pieces that qualify for an automation postage rate and a reduced per piece fee (see 7.0). Domestic BRM may not be distributed to foreign countries. Standards for International Business Reply Service (IBRS) are in the International Mail Manual.
1.2Payment Guarantee
The permit holder guarantees payment of the applicable First-Class Mail or Priority Mail postage, plus a per piece fee, on all returned BRM. This includes any incomplete, blank, or empty BRM cards and envelopes and any mailable matter with a BRM label affixed.
1.3Services
No special services (e.g., certified, insured, registered) are permitted with BRM.
1.4Address
The delivery address on a piece of BRM may not be altered to redirect the mailpiece to any address other than the one preprinted on the piece.
1.5Official Mail
Authorized users of official (penalty) mail may distribute BRM subject to the additional standards in E060, which supersede any conflicting standards in S922.
1.6Intentions of the Permit Holder
BRM may not be used for any purpose other than that intended by the permit holder, even when postage is affixed. In cases where a BRM card or letter is used improperly as a label, the USPS treats the item as waste.
1.7Samples
Prior to printing, permit holders are encouraged, but not required, to submit preproduction samples of BRM to the USPS for approval. QBRM pieces require USPS approval (E150).
1.8Error Notification
If the USPS discovers a BRM format error, the responsible permit holder or authorized agent receives written notification of the error. The permit holder must correct the error and make sure that all future BRM pieces meet appropriate specifications. The repeated distribution of BRM with format errors is grounds for revoking a BRM permit (2.6).
2.0 Permits
2.1Required
Any mailer who wants to distribute BRM must apply for and receive a permit. The permit number, city, and state where the permit is held must appear on all pieces of BRM.
2.2Application Process
[8-23-04] The mailer may apply for a BRM permit using one of the following processes:
a. Form 3615. The mailer submits a completed Form 3615 to the post office issuing the permit and pays the annual permit fee. If a completed Form 3615 is already on file for the mailer at that office for other permits then the mailer must submit the annual permit fee and the USPS amends Form 3615 by adding the BRM authorization.
b. Online. The mailer applies online at www.usps.com. Online application is available only for BRM permits issued for certain post offices, determined by logging on to www.usps.com/replymail and entering the 5-digit ZIP Code of the post office where the mailer wants the BRM permit issued. If the online application option is not available for a 5-digit ZIP Code, the applicant must apply using Form 3615.
2.3Annual Permit Fee
A permit fee must be paid once each 12-month period at each post office where a BRM permit is held. Payment of the permit fee is based on the anniversary date of the permit’s issuance. The fee may be paid in advance only for the next 12 months and only during the last 60 days of the current service period. The fee charged is that which is in effect on the date of payment. Agents authorized by a permit holder under 8.0 are not required to pay an annual permit fee at the post office where their BRM is received.
2.4Renewal of Annual Permit Fee
An annual renewal notice is provided to each BRM permit holder by the USPS. The notice and the payment for the next 12 months must be returned by the expiration date to the post office that issued the permit. After the expiration date, if the permit holder has not paid the annual permit fee, then returned BRM pieces are treated as follows:
a. Postcards of no obvious value are treated as waste and disposed of at the delivery unit.
b. Pieces (excluding postcards) with a return address are endorsed “Business Reply Permit Canceled” and are returned to the sender.
c. Pieces without a return address are endorsed “Business Reply Permit Canceled” and forwarded to the mail recovery center for handling.
2.5Other Post Offices
A permit holder may distribute BRM through any post office for delivery at any post office under 8.0.
2.6Revocation of a Permit
The USPS may revoke a BRM permit because of format errors or for refusal to pay permit fees (i.e., annual, accounting, quarterly, monthly), postage, or per piece fees. If the permit was revoked due to format errors, then a former permit holder may obtain a new permit and permit number by completing and submitting a new Form 3615, paying the required BRM annual permit fee, paying a new annual accounting fee (if applicable), and, for the next 2 years, submitting two samples of each BRM format to the appropriate post office for approval.
3.0 Postage, Per Piece Fees, and Accounting Fees
3.1Postage
Each piece of returned BRM is charged the applicable single-piece First-Class Mail or Priority Mail postage (R100). Cards must meet the standards in C100 to qualify for card rate postage. Any card larger than those dimensions is charged the applicable First-Class Mail letter rate. For Priority Mail over 1 pound, if the zone cannot be determined from a return address or cancellation, then the permit holder is charged zone 4 postage for the weight of the piece. For QBRM, see 7.0.
3.2Per Piece Fees
Per piece fees listed in R900.4.0 are charged for each piece of returned BRM (in addition to postage in 3.1). If a permit holder has not paid an annual accounting fee and established a BRM advance deposit account, then the basic (higher) BRM per piece fee must be paid. If a permit holder has paid the annual accounting fee and has established a BRM advance deposit account, then the high-volume (lower) BRM per piece fee is paid. For QBRM, see 7.0.
3.3Advance Deposit Account and Annual
Accounting Fee
A permit holder may choose to pay an annual accounting fee and establish an advance deposit account, which qualifies returned BRM pieces for the high-volume per piece fee. The accounting fee must be paid once each 12-month period at each post office where a permit holder holds an advance deposit account. Payment of the accounting fee is based on the anniversary date of the initial payment. The fee may be paid in advance only for the next 12-month period and only during the last 60 days of the current 12-month period. The fee charged is that which is in effect on the date of payment. A separate advance deposit account solely for BRM is not required. An advance deposit account can be used for BRM under these conditions:
a. For each withdrawal, only one statement is provided for each annual accounting fee paid.
b. If a permit holder distributes BRM with different addresses (including post office box numbers) under the same permit number going to the same delivery unit and has only one business reply account, then the BRM is separated by each different address but only one statement is provided and only one annual accounting fee is paid.
c. The permit holder must pay an annual accounting fee for each separate statement (accounting) requested. If only one annual accounting fee is paid, then the permit holder receives only one statement.
d. The permit holder must maintain a balance in the BRM advance deposit account that is sufficient to cover postage and per piece fees for returned mailpieces. The permit holder is notified if funds are insufficient. After 3 calendar days, if no funds are deposited, then BRM on hand is charged the basic BRM per piece fee and postage and charges are collected from the permit holder (e.g., in cash) prior to delivery.
e. BRM addressed to several different firms at the same delivery unit may be delivered to an agent authorized by a valid BRM permit holder. The agent pays one annual accounting fee for all the firms represented by the agent in the same delivery unit. If the agent, or any of the firms represented by the agent, wants a separation of charges, then separate (additional) accounting fees must be paid.
3.4Renewal of Annual Accounting Fee
An annual renewal notice is provided to each BRM permit holder with a BRM advance deposit account. The notice and the payment for the next 12 months must be returned by the expiration date to the post office that holds the advance deposit account. After the expiration date, if the permit holder has not paid the annual accounting fee but still has a valid BRM permit, returned BRM pieces no longer qualify for the high-volume BRM per piece fee and are charged the basic BRM per piece fee in R900.4.1.
3.5Combined Pieces as a Single Item
Two or more BRM pieces may be mailed as a single piece if the BRM pieces are identically addressed and prepared for mailing in accordance with C100. The permit holder is charged postage based on the total weight of the combined piece plus one per piece fee. If the combined pieces become separated, then the permit holder must pay postage and a per piece fee for each individual piece. Combined pieces are not eligible for QBRM postage rates or per piece fees.
3.6With Postage Affixed
BRM with postage affixed is handled the same as other BRM. No effort is made to identify or separate BRM pieces with postage affixed. The amount of affixed postage is not deducted from the postage or per piece fees owed. The permit holder may request a refund or credit for postage affixed to BRM under P014.
3.7Payment Options
Permit holders may pay for postage and per piece fees on returned pieces by cash or check upon delivery, through a regular postage due account (P011.3.1), or through a BRM advance deposit account. A regular postage due account does not qualify the permit holder for high-volume BRM per piece fees, and no annual accounting fee is charged to maintain the account.
4.0 Mailpiece Characteristics
4.1Paper Weight
BRM paper envelopes must have a minimum basis weight of 20 pounds (500 17- by 22-inch sheets). Other pieces (i.e., cards and self-mailers) must meet the basis weight requirements in C810.
4.2Nonpaper Envelopes
USPS Engineering must approve nonpaper envelopes for mailability. See C810.
4.3Envelope Reflectance
Envelope material must not have a red fluorescence exceeding 4.0 phosphor meter units.
4.4Sealing and Edges
All BRM pieces must meet the general mailability standards in C010 and must have straight (90 degree) edges. BRM pieces are not mailable if they are sealed with wax, clasps, string, staples, or buttons.
4.5Window Envelopes
The following standards apply to BRM prepared in an open-panel or a covered window envelope:
a. Open panel window envelopes:
(1) The mailpiece must meet the applicable standards in A800 for address/window clearance or C840 for barcode/window clearance for envelopes with an address window.
(2) The “No Postage Necessary” imprint, the business reply legend, horizontal bars, and the facing identification mark (FIM) must be printed directly on the envelope. Other required and optional elements in 5.0 may be printed on the insert appearing through the address window.
(3) The address showing through the window must be that of the permit holder or an authorized representative.
b. Covered window envelopes:
(1) The “No Postage Necessary” imprint, the business reply legend, and the horizontal bars must be printed either directly on the envelope or on the insert appearing through the covered window. The minimum size of the information appearing in the covered window is 2 inches high and 4-1/4 inches long. The FIM must be printed on the envelope as specified in C100. A clear space of at least 1/8 inch is required between any BRM format requirement and the top, bottom, and side edges of the window, and must remain when the insert is moved to its full limits in each direction within the envelope.
(2) The window cover must be of a nontinted clear or transparent material (e.g., cellophane or polystyrene) that permits the barcode and its background, as viewed through the window material, to meet the reflectance standards in C840.5.0. The edges of the window cover must be securely glued to the envelope.
(3) The address on the insert showing through the window must be that of the permit holder or an authorized representative.
4.6Self-Mailers and Reusable Mailpieces
In addition to the standards in 4.0 and 5.0, self-mailers and reusable mailpieces must meet the standards in C810. Permit holders must provide instructions to the user for re-folding and sealing (see C010) so that upon return the piece meets sealing and folding requirements in C810.
4.7Cards
Cards must meet the standards in C100.
4.8Labels
For general use, the minimum size of a BRM label is 2 inches high and 3 inches long. BRM labels are not required to have a FIM or a ZIP+4 barcode, but all other format standards in 5.0 must be met. In cases where a BRM card or letter is used improperly as a label, the USPS treats the item as waste. See 4.9 for labels for letter-size pieces.
4.9Labels for Letter-Size Pieces
The following standards apply to BRM labels for use on letter-size pieces:
a. The minimum size of a BRM label is 2-5/8 inches high and 4-1/4 inches long. All format elements, including a FIM, must be printed on the label. BRM labels cannot include a barcode. Exception: The vertical series of horizontal bars must be at least 3/4-inch high. The back of the label must be coated with a permanent adhesive strong enough to firmly attach the label to an envelope.
b. The permit holder must provide instructions to the user describing how the label should be applied to a mailpiece and what precautions must be observed when applying the label (see Exhibit 4.9). A pictorial diagram showing proper placement of the label must be included with the instructions. At a minimum, the instructions must include the following directions:
(1) Place the label squarely in the upper right corner of the envelope.
(2) Do not write on the envelope or label.
(3) Do not use a window envelope, an envelope that is less than 1 inch higher than the label an envelope that is more than 4-1/2 inches high, or an envelope with any printing other than a return address.
(4) Do not use tape to affix the label.
c. When the label is affixed to an envelope, the address must be placed within the OCR read area (see A010.1.3).
d. Pieces with business reply labels cannot qualify for QBRM rates.
Exhibit 4.9Instructions for Affixing Business
Reply Label
5.0 Format Elements
5.1General
All pieces of BRM are subject to these format elements. Pieces of QBRM and bulk weight averaged nonletter-size BRM are subject to additional format standards listed in 7.0 and 9.0, respectively. BRM format elements are shown in Exhibit 5.1.
5.2Printing and Print Reflectance
All forms of printing are permissible if legible to the satisfaction of the USPS. Handwriting, typewriting, and handstamping may not be used to prepare BRM. Printed borders are not permitted on letter-size BRM, but are permitted on business reply labels and cartons and envelopes greater than 6-1/8 inches high or 11-1/2 inches long or 1/4 inch thick. All ink colors are acceptable if the piece meets the appropriate reflectance standards in C840.
Exhibit 5.1Business Reply Mail Format
5.3“No Postage Necessary”
Imprint
The imprint “NO POSTAGE NECESSARY IF MAILED IN THE UNITED STATES” must be printed in the upper right corner of the address side of the piece. The imprint must not extend more than 1-3/4 inches from the right edge of the piece.
5.4Business Reply Legend
The legend “BUSINESS REPLY MAIL” or “BUSINESS REPLY LABEL,” as appropriate, must appear on all pieces. This legend must appear above the address in capital letters at least 3/16 inch high. At the permit holder’s discretion, the business reply legend may be surrounded by a rule or border.
5.5Permit Number and Postage Endorsement
Directly below the business reply legend, the words “FIRST-CLASS MAIL PERMIT NO. [NO., CITY, STATE]” (representing the permit holder's number and post office that issued the permit) must appear in capital letters. Directly below that, the endorsement “POSTAGE WILL BE PAID BY ADDRESSEE” must appear in capital letters. At the permit holder’s discretion, the permit number and postage endorsement may be surrounded by a rule or border.
5.6Delivery Address
The complete address (including the permit holder’s name, delivery address, city, state, and BRM ZIP Code) must be printed directly on the piece, subject to these conditions:
a. Preprinted labels with only delivery address information (including a ZIP+4 barcode under 6.0) are permitted, but the permit holder’s name and other required elements must be printed directly on the BRM piece.
b. On letter-size pieces, the complete delivery address must appear within the OCR read area (see A010.1.3).
c. There must be at least a 1/2-inch clearance between the ZIP Code and the horizontal bars.
d. A unique ZIP Code (i.e., firm ZIP Code) must not be used for BRM unless the ZIP Code has been assigned specifically for BRM. A unique 4-digit add-on to denote BRM may not be used with a unique 5-digit ZIP Code not specifically assigned to BRM.
5.7Horizontal Bars
A vertical series of horizontal bars parallel to the length of the piece must be printed directly below the imprint “NO POSTAGE NECESSARY IF MAILED IN THE UNITED STATES.” The bars must be uniform in length, at least 1 inch long and 1/16 inch to 3/16 inch thick, and evenly spaced. On letter-size nonbarcoded BRM, the bars must not extend below the delivery address line (the line above the line containing the ZIP Code). On barcoded BRM, the bars must not extend lower than 5/8 inch from the bottom edge of the piece.
5.8Facing Identification Mark (FIM)
A FIM must be printed on all letter-size BRM and on business reply labels affixed to letter-size mail (see 4.9). FIM B must be used with BRM without a barcode. FIM C must be used with any BRM printed with a barcode. The FIM must meet the physical standards in C100.
5.9Company Logo
A company logo is permitted:
a. On nonbarcoded BRM, if it is placed outside the OCR read area (see A010.1.3).
b. On letter-size barcoded BRM, if it is placed no lower than 5/8 inch from the bottom edge of the piece.
c. On any piece, if the logo does not interfere with any required format elements.
6.0 Additional Standards for Letter-Size Barcoded BRM
In addition to the format standards in 5.0, letter-size BRM enclosed in automation rate mailings and all QBRM must be ZIP+4 barcoded. Other BRM may be barcoded at the permit holder’s option. Barcoded BRM must meet the barcode standards in C840, the envelope basis weight standards in 4.1, all other mailpiece design standards in C810 (including thickness), and these standards:
a. Permit holders must use the ZIP+4 codes and equivalent barcodes assigned by the USPS. Delivery point barcodes are not permitted on BRM.
b. The ZIP+4 barcode must be placed on the address side of the piece and positioned in either of these two locations:
(1) As part of the delivery address block under C840 if printed on an insert appearing through a window envelope or on an address label affixed directly to the piece.
(2) Within the barcode clear zone in the lower right corner of the piece if printed directly on the piece.
7.0 Additional Standards for Qualified Business Reply Mail (QBRM)
7.1Description
Qualified business reply mail (QBRM) is a subset of business reply mail. Permit holders distribute automation-compatible letter-size pieces that qualify for automation postage rates and reduced per piece fees. QBRM postage and per piece fees must be deducted from a BRM advance deposit account.
7.2Eligibility
To qualify for QBRM, pieces must meet the eligibility requirements in E150.
7.3Authorization
BRM permit holders must apply for authorization to participate in QBRM under E150.
7.4Postage
Each piece of returned QBRM is charged the automation postage rate for QBRM pieces in R100.3.0. Pieces that do not meet the format requirements for QBRM cannot qualify for automation postage rates and are charged First-Class Mail postage according to 3.1.
7.5Per Piece Fees
Per piece fees listed in R900.4.3 are charged for each piece of returned QBRM (in addition to postage in 7.4). Pieces that do not meet the format requirements for QBRM cannot qualify for QBRM per piece fees and are charged the high-volume BRM per piece fees in R900.4.2.
7.6Annual Accounting Fee and Advance Deposit
Account
Permit holders are required to pay QBRM postage and per piece fees through a BRM advance deposit account, which requires payment of an annual accounting fee (see 3.3).
7.7Quarterly Fee for High-Volume QBRM
Mailers may choose to pay a quarterly fee in addition to the annual accounting fee. Payment of the quarterly fee entitles mailers to a lower per piece fee (the high-volume QBRM per piece fee listed in R900.4.4). The quarterly fee and annual accounting fee must be paid at each post office where mail is returned and for each separate billing desired. Mailers are eligible for the high-volume QBRM rates and per piece fees only for the time they pay the quarterly fee (i.e., mailers can opt out of the quarterly fee and related high-volume QBRM per piece fees simply by not paying the fee for the next quarter). The quarterly fee cannot be paid or renewed retroactively to receive a lower per piece fee on pieces already paid for and delivered. The quarterly fee can be paid for any three consecutive calendar months.
7.8Payment Period for Quarterly Fee
The quarterly fee must be paid in advance for at least one but no more than four quarterly periods. A quarterly period begins on either the first day of the month (if a mailer pays on or before the 15th of the month) or the first day of the following month (if a mailer pays after the 15th of the month) and continues for three consecutive calendar months. A mailer who pays the quarterly fee is entitled to the high-volume QBRM per piece fee from the date of payment through the end of the quarterly period. The fee paid is that which is in effect on the date of payment.
8.0 BRM Distributed and Received by Agents of a Permit Holder
8.1Description
Permit holders may give permission to subsidiary offices, agents, or authorized representatives to distribute and receive BRM using a single (corporate) permit number. BRM pieces are distributed by and returned to agents, who pay postage and per piece fees on those returned pieces. Agents may use any type of BRM service.
8.2Permit
The main permit holder or “corporate” office applies for the permit number and pays the permit fee. The agent must present a letter of authorization from the permit holder showing the name, address, and telephone number of the local agent authorized to receive the BRM to the post office where the BRM is to be returned. Any time there is a change to the original permit application or the authorization letter, each agent must provide an amended letter of authorization to their local post office.
8.3Annual Permit Fee
The annual permit fee must be paid by the permit holder (2.3). Agents do not pay a separate annual permit fee but must submit evidence (usually a copy of Form 3544) to the local office once each 12-month period to show that the annual permit fee has been paid. This evidence is not required if the permit holder has a centralized account processing system (CAPS) account through which the local post office can determine that the permit fee has been paid.
8.4Postage, Per Piece Fees, and Annual Accounting
Fees
Agents receiving BRM or QBRM pay the postage, per piece fees, and annual accounting fees listed in R900.4.0 for the type of service received. The agent may choose to pay an annual accounting fee and establish a BRM advance deposit account. The agent receiving BRM is responsible for paying all postage and per piece fees.
8.5Payment Guarantee
The permit holder is ultimately responsible for postage and per piece fees for all pieces returned under that permit number. If a local agent refuses or neglects to pay postage or per piece fees on returned pieces, then those pieces are forwarded to the post office that issued the original permit for collection of postage and per piece fees from the permit holder. Once forwarded to the permit holder, these pieces cannot qualify for QBRM postage and per piece fees. The permit holder’s refusal to accept and pay the required postage and per piece fees for BRM offered for delivery is grounds for immediate revocation of the BRM permit (2.6).
8.6Format
BRM distributed by agents must meet all required format standards in 4.0 and 5.0. Authorized representatives distributing BRM on behalf of a permit holder must have the permit holder’s name and permit number printed on the BRM and their own names and addresses printed below the permit holder’s name, except:
a. When the agent is a branch of an authorized business.
b. The permit holder notifies a post office that authorized representatives may use the permit holder’s permit number without printing the permit holder’s name.
9.0 Bulk Weight Averaged nonletter-size BRM
9.1Description
Bulk weight averaging is a method of counting, rating, and billing incoming nonletter-size BRM based on principles of mathematical statistics. Probability sampling techniques are used to measure the characteristics of the total BRM volume by examining a fraction of the volume. Statistically valid samples that are drawn from the incoming BRM volume each postal accounting period are used by post offices to compute average postage due per pound and average piece count per pound factors. The net bulk weight of mail received is multiplied by these conversion factors to get the estimated volume received and postage and fee amounts.
9.2Eligibility
BRM pieces rated by the weight averaging method must:
a. Meet the basic standards for BRM in S922.
b. Not be letter-size (C050) or card-size (C100).
9.3Postage, Per Piece Fees, and Other Fees
Returned pieces of bulk weight averaged nonletter-size BRM are charged postage and per piece fees according to R900.4.5. Permit holders participating in bulk weight averaged nonletter-size BRM must pay an annual accounting fee (see 3.3) and a monthly maintenance fee (R900.4.5).
9.4Application Procedures
A permit holder who wants to use bulk weight averaged BRM for nonletter-size pieces must submit a written request to the postmaster of the office where the BRM permit is held. The postmaster forwards this information to the manager, Customer Service Support, USPS Headquarters (see G043 for address). The request must include the following information:
a. Permit holder’s name and address.
b. Name and location of the post office at which BRM will be received and a CAPS account number, if available.
c. Information about the number of pieces expected to be returned over a 24-hour period and a 30-day period, and a breakdown of the weight distribution of those pieces (in nearest ounces or pounds) (e.g., X number of 3-ounce pieces, Y number of 4-ounce pieces, and Z number of 5-ounce pieces).
d. Based on the estimated volume in 9.4c, a 24-hour estimate and a 30-day estimate of postage and per piece fees using the postage and charges listed in R900.4.5.
e. A statement indicating whether the piece volume has seasonal variation and, if applicable, estimates of monthly volumes for a 12-month period.
9.5Authorization
The permit holder's request will be reviewed and approved by the manager, Customer Service Support, USPS Headquarters. If the request is approved, then a letter of authorization is sent to the permit holder from the post office where the BRM permit is held. The permit holder signs a service agreement and, if necessary, is assigned a post office box address.
9.6Denial of Authorization
If the permit holder's request is not approved, then the post office sends a written notice, giving reasons for the denial. The permit holder has 15 days following receipt of the notice to file a written appeal of the decision with the postmaster and to furnish further information. If the postmaster still finds that the application should be denied, then the postmaster forwards the file to the manager, Customer Service Support, USPS Headquarters, who issues a final written decision to the permit holder.
9.7Revoking Authorization
To revoke authorization for bulk weight averaging, the postmaster sends written notice to the permit holder. A postmaster may terminate authorization for bulk weight averaged BRM for any of the following reasons:
a. The permit holder provided incorrect or incomplete information on the request for authorization.
b. The permit holder’s BRM pieces no longer meet the eligibility requirements in S922.
c. The USPS finds that bulk weight averaging no longer provides adequate revenue protection.
d. The permit holder no longer desires to participate in bulk weight averaging.
9.8Notice and Appeal
Termination takes effect 15 days from the permit holder’s receipt of the notice unless the permit holder files a written appeal within that period with the postmaster. The postmaster forwards the permit holder’s appeal together with all pertinent information to the manager, Customer Service Support, USPS Headquarters, who issues a final agency decision to the permit holder. The permit holder may continue to use the bulk weight averaging method until a final decision is made on the appeal.
DMM Issue 58 Updated 12-9-04