United States Government Accountability Office

GAO Report to Congressional Committees

U.S. POSTAL 

SERVICE 

Mail-Related 

Recycling Initiatives 

and Possible 

Opportunities for 

Improvement 

June 2008

 

GAO-08-599 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

June 2008

U.S. POSTAL SERVICE

Mail-Related Recycling Initiatives and Possible 

Opportunities for Improvement 

Highlights of GAO-08-599, a report to 

congressional committees 

USPS and the mailing industry have undertaken numerous initiatives to 

increase (1) the recycling of mail-related materials and (2) the amount of mail 

with environmentally preferable attributes, such as mail that uses recycled 

paper. USPS has five key recycling-related initiatives underway. For example, 

USPS recently established annual goals to increase its revenue from mailrelated recycling from $7.5 million to $40 million from fiscal years 2007 to 

2010. However, by excluding savings that result from lower waste disposal

costs—which accompany increased recycling—the goals do not reflect the 

full financial benefit attributable to mail-related recycling. USPS also has 

launched a pilot recycling program in New York City, but it is not known 

whether USPS will require its managers elsewhere to adopt applicable 

“lessons learned” from the pilot. Representatives of the mailing industry and 

other stakeholders also have undertaken a wide range of initiatives to, among 

other actions, increase the amount of mail that is recycled. For example, three 

mailing industry associations recently introduced separate awareness 

campaigns to encourage mail recipients to recycle their catalogs, envelopes, 

and magazines. In addition, the Direct Marketing Association—whose 

members collectively send about 80 percent of all Standard Mail—is 

undertaking several initiatives, including an effort to encourage mailers to use 

environmentally preferable mail attributes. 

USPS, mailing industry, and other stakeholders GAO interviewed identified 

five opportunities that USPS could choose to undertake to increase its 

recycling of mail-related materials and to encourage mailers to increase the 

amount of mail with environmentally preferable attributes. The five 

opportunities stakeholders cited most frequently were for USPS to: (1) 

implement a program for recognizing mail-related recycling achievements; (2) 

increase awareness among mail recipients that mail is recyclable and 

encourage them to recycle their mail; (3) collaborate with parties interested in

increasing the supply of paper fiber available for recycling; (4) establish a 

special, discounted postal rate—or “Green Rate”—as a means of inducing 

mailers to adopt environmentally preferable attributes; and, (5) initiate a “mail 

take-back” program in locations that do not have access to municipal paper 

recycling. Each of these opportunities appears to be consistent with the 

agency’s long-standing commitment to environmental leadership and the 

Postmaster General’s recent commitments to minimize the agency’s impact on 

every aspect of the environment and to act as a positive environmental 

influence in U.S. communities. Based on GAO’s analysis, however, USPS 

would need to assess several factors including cost, feasibility (including 

logistical considerations), and mission compatibility in deciding whether to 

adopt these opportunities. For example, depending on the magnitude of 

variance between the expected costs and revenues, USPS may find 

implementing one or more of the opportunities unacceptable. This is, in part, 

because USPS faces multiple short- and long-term pressures in improving its

operational efficiency, increasing its revenues, and controlling its costs—

some of which are increasing faster than the overall inflation rate. 

In 2006, the U.S. Postal Service 

(USPS) discarded about 317,000 

tons of undeliverable-as-addressed

advertising mail. Such mail can be 

disposed of using incineration, 

landfills or through other methods. 

USPS recently committed to

minimizing the agency’s impact on

every aspect of the environment. 

Recycling undeliverable advertising 

mail can help USPS achieve this 

commitment, while generating 

revenue and reducing its costs and

financial pressures. 

In response to the 2006 Postal

Accountability and Enhancement Act, 

this report addresses (1) recent mailrelated recycling accomplishments 

(initiatives) undertaken by USPS, the

mailing industry, and others and (2) 

additional recycling opportunities that 

USPS could choose to engage in, or 

influence mailers to undertake. To 

conduct this study, GAO analyzed 

relevant data and documents, visited

USPS and other facilities, and

interviewed about 40 stakeholders. 

What GAO Recommends

GAO recommends, among other 

actions, that USPS (1) require

managers at other facilities to adopt 

applicable lessons learned from its 

New York City recycling pilot and (2) 

adopt the opportunities identified in

this report that are feasible, 

compatible with USPS’ mission, and 

appropriate in view of cost and other

considerations. USPS agreed with 

three of GAO’s recommendations and 

stated that it is acting to implement 

them. USPS also agreed, in principle,

with the remaining recommendation 

to adopt lessons learned from its pilot. 

To view the full product, including the scope 

and methodology, click on GAO-08-599. 

For more information, contact Katherine 

Siggerud at (202) 512-2834 or 

siggerudk@gao.gov. 
Contents 

Letter 1

Results in Brief 4 

Background 6

USPS and the Mailing Industry Have Undertaken Numerous MailRelated Recycling Initiatives 11 

Stakeholders Cited Five USPS Mail-Related Recycling 

Opportunities, but USPS Would Need to Assess Several Factors 

in Deciding Whether to Adopt Them 31 

Conclusions 43

Recommendations for Executive Action 44 

Agency Comments and Our Evaluation 45 

Appendix I Objectives, Scope, and Methodology 47 

Appendix II Other USPS Actions to Increase the Amount of 

Mail with Environmentally Preferable Attributes 51 

Appendix III Depiction of Various Mail-Related Recycling Logos 52 

Appendix IV Other Stakeholder Initiatives to Increase the Amount 

of Mail with Environmentally Preferable Attributes 54 

Appendix V DMA’s List of 15 Environmentally Preferable 

Business Practices 57 

Appendix VI Comments from USPS 59 

Appendix VII GAO Contact and Staff Acknowledgments 61 

Page i GAO-08-599 U.S. Postal Service 
Tables 

Table 1: Relevant Goals of the Five Greening the Mail Task Force 

Subcommittees 21

Table 2: Stakeholders Interviewed 48 

Figures 

Figure 1: Mail-Related Recycling Logos 52 

Figure 2: Logos Indicating Paper Products Contain Recycled 

Materials or Are Recyclable 53 

Abbreviations 

DMA Direct Marketing Association 

UAA undeliverable-as-addressed 

USPS United States Postal Service 

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

copyrighted images or other material, permission from the copyright holder may be 

necessary if you wish to reproduce this material separately. 

Page ii GAO-08-599 U.S. Postal Service 
United States Government Accountability Office

Washington, DC 20548 

June 3, 2008

Congressional Committees 

During fiscal year 2007, United States Postal Service (USPS) customers 

sent approximately 104 billion pieces of mail (mailpieces) as Standard 

Mail, the primary class of mail used for advertising. Over time, most of 

these mailpieces were presumably discarded as waste. Depending on how 

the discarded mailpieces are disposed of, they could be recycled, placed 

into landfills, or incinerated. The U.S. Environmental Protection Agency 

reports that during 2006, Standard Mail comprised about 2.3 percent (5.9 

million tons) of all municipal solid waste. Of this amount, recycling efforts 

captured about 39 percent, while landfills or incinerators received the 

remaining quantity. USPS discarded about 6.1 billion undeliverable-asaddressed (UAA) Standard Mail mailpieces (about 317,000 tons) in 2006, 

while mailers discarded the remainder.1

 With the exception of UAA 

Standard Mail, the responsibility for recycling discarded mail primarily lies 

with mail recipients. 

USPS, which receives only a small portion of its funding from federal 

appropriations, is expected to generate sufficient annual revenue to cover

its costs. In fiscal year 2007, however, USPS’ operating costs exceeded its 

revenues by over $5 billion, largely due to the agency’s advance payments 

for retiree health benefits. Furthermore, USPS expects to incur substantial 

additional costs that will need to be offset by revenue increases and 

improved operating efficiencies. USPS has reported that mixed paper (i.e.,

UAA mailpieces, including newsprint, and mail discarded by recipients in 

postal facility lobbies) account for up to 70 percent of its waste stream. 

Recycling these materials provides USPS with a means to generate 

substantial revenues, significantly reduce its waste disposal costs, and 

improve its financial position. In addition, because recycling discarded 

mail-related materials results in a variety of environmental benefits, 

including reductions in the amount of mail incinerated or placed in 

 1

 Approximately 6 percent of all Standard Mail was UAA in 2004. USPS returns a small 

portion of UAA Standard Mail annually to mailers, at their request, and discards the

remainder.

Page 1 GAO-08-599 U.S. Postal Service
landfills,2

 recycling these materials provides USPS with a means to 

enhance its long-standing commitment to environmental leadership. 

During fiscal year 2007, revenue generated from Standard Mail comprised 

about 28 percent ($20.8 billion) of USPS’ total revenue, and Standard Mail 

constituted the largest class of mail by volume (about 49 percent of 212 

billion mailpieces). The prevalence of Standard Mail is expected to 

increase, in part, because businesses, non-profit organizations, and others

view it as an effective way to (1) provide consumers with information 

about their products and services and (2) solicit contributions from mail 

recipients. Some critics, however, view Standard Mail as an annoyance 

that also poses identify theft concerns and negatively impacts the 

environment. In response, numerous state legislatures introduced “Do Not 

Mail” bills that, if enacted, would require mailers to remove registered 

individuals from their mailing lists (similar to the national “Do Not Call” 

registry).3

In response to the 2006 Postal Accountability and Enhancement Act and 

agreements reached with relevant congressional offices, this report 

addresses (1) recent mail-related recycling accomplishments (initiatives)4

undertaken by USPS, the mailing industry, and others and (2) additional

recycling opportunities that USPS could choose to engage in, or influence 

mailers to undertake. Pursuant to our legislative mandate, we issued a 

report on our interim results on December 20, 2007.5

 This report updates 

our interim report and describes in more detail the key recycling initiatives

that recently have been undertaken by USPS, the mailing industry, and 

other stakeholders. These initiatives include efforts to recycle mail-related 

materials,6

 including UAA Standard Mail, and to increase the amount of 

 2

 Recycling also helps reduce the incidence of water and air pollution and helps lower 

greenhouse gas emissions, among other benefits. Furthermore, manufacturing paper from

recycled paper fiber may require less electricity, fuel, and water. 

3

 In addition, Forest Ethics, an environmental non-profit organization, recently initiated an 

online petition for a national Do Not Mail Registry. 

4

 Because many of USPS’ mail-related recycling efforts are in the early stages of their 

implementation, we discuss these efforts as “initiatives,” rather than as “accomplishments.” 

5

 GAO, Postal Service and Mailing Industry Mail-Related Recycling: Accomplishments 

and Postal Opportunities-Interim Results, GAO-08-348R (Washington, D.C.: 

Dec. 20, 2007). 

6

 Mail-related materials include UAA mail, mail discarded in USPS facilities, and other 

materials related to mail such as plastic wrappings and cardboard. 

Page 2 GAO-08-599 U.S. Postal Service
mail with environmentally preferable attributes. Mail with environmentally 

preferable attributes includes mail that (1) contains paper with recycled 

paper fiber (recycled paper); (2) uses paper from responsibly-managed 

forests (certified paper);7

 (3) is designed to use materials efficiently, (such 

as “two-way” envelopes); (4) is accurately addressed for delivery; and (5) 

is targeted to mail recipients who may wish to receive it. This report also 

describes additional stakeholder-identified opportunities for USPS to 

engage in (or influence mailers to undertake) mail-related recycling 

initiatives, and identifies factors such as cost; feasibility, including 

logistical considerations; and mission compatibility that USPS would need 

to assess prior to adopting the opportunities. 

To accomplish our objectives we, among other activities, (1) interviewed a 

wide range of USPS officials and stakeholders from about 40 other 

organizations, including representatives from mailing, paper recycling, and 

environmental advocacy organizations; (2) toured various facilities, 

including USPS facilities in Baltimore and Philadelphia, a paper recycling 

facility, and a printing facility; (3) attended meetings of the “Greening the 

Mail Task Force”—a committee of USPS, mailing industry, and other 

stakeholders that addresses environmental issues regarding the mail; and 

(4) reviewed and analyzed relevant documentation. We discussed matters 

related to recycling several classes of mail with stakeholders; however, we 

primarily focused on Standard Mail because of (1) its increasing 

prominence in the mail stream; (2) its contribution to the municipal solid 

waste stream; (3) USPS’ responsibility for discarding large volumes of 

UAA Standard Mail; and (4) the issues critics cite related to Standard Mail, 

which are reflected in numerous “Do Not Mail” state legislative initiatives. 

While there are a variety of ways to consider the environmental impacts of 

mail, this report focuses on the role recycling plays in eliminating mail and 

mail-related materials from municipal solid waste, increasing USPS’ 

revenue, decreasing USPS’ waste disposal costs, and enhancing USPS’ 

commitment to environmental leadership. Appendix I provides a more 

detailed explanation of our scope and methodology. 

We conducted this performance audit from April 2007 to June 2008 in 

accordance with generally accepted government auditing standards. Those 

standards require that we plan and perform the audit to obtain sufficient, 

appropriate evidence to provide a reasonable basis for our findings and 

 7

 Several forest certification programs exist. The programs are intended to recognize and 

promote environmentally preferable forestry management practices. 

Page 3 GAO-08-599 U.S. Postal Service
conclusions based on our audit objectives. We believe that the evidence 

obtained provides a reasonable basis for our findings and conclusions 

based on our audit objectives. 

USPS and the mailing industry have undertaken numerous initiatives to 

increase (1) the volume of mail-related materials recycled and (2) the 

amount of mail with environmentally preferable attributes. USPS has five 

key recycling-related initiatives underway. For example, USPS recently 

established annual goals to increase its revenue from mail-related 

recycling from $7.5 million in fiscal year 2007 to $40 million in fiscal year 

2010. These goals do not reflect the full financial benefit attributable to 

mail-related recycling, however, because they exclude the savings that 

result from lower waste disposal costs that accompany increased 

recycling. At the conclusion of our review, USPS had not agreed to revise 

its goals or to adopt additional goals that reflect its full financial benefit.

Furthermore, while USPS intends to develop a plan to help it achieve its 

recycling revenue goals, it is not clear whether this plan will (1) specify 

how progress toward the goals will be measured or (2) ensure that the 

data USPS will use to measure its progress are accurate, reliable, and 

collected using a consistent method. Similarly, although USPS also has 

launched a pilot recycling program in New York City, it is not clear 

whether, or to what extent, USPS will require its managers at other 

facilities to adopt, as applicable, feasible, mission compatible, and 

appropriate in view of cost and other considerations, the lessons learned 

from the pilot. USPS also developed, among other initiatives, a task force 

to increase the amount of mail with environmentally preferable attributes. 

Representatives of the mailing industry and other stakeholders also have 

undertaken a wide range of initiatives to, among other actions, increase 

the amount of mail that is recycled. For example, three mailing industry 

associations recently introduced separate recycling awareness campaigns 

to encourage mail recipients to recycle their catalogs, envelopes, and 

magazines. Other stakeholders, such as the National Recycling Coalition;

Time, Inc.; and Verso Paper, have initiated a campaign to increase the 

volume of catalogs and magazine recycled in selected cities. In addition, 

the Direct Marketing Association—whose members collectively send 

about 80 percent of all Standard Mail—is undertaking several initiatives, 

including an effort to encourage mailers to use environmentally preferable

mail attributes. 

Results in Brief 

USPS, mailing industry, and other stakeholders we interviewed identified 

five opportunities that USPS could choose to undertake to increase the 

volume of mail-related materials it recycles and to encourage mailers to 

Page 4 GAO-08-599 U.S. Postal Service
increase the amount of mail with environmentally preferable attributes. 

The five opportunities stakeholders cited most frequently were for USPS 

to: 

• Implement a program for recognizing mail-related recycling achievements.

• Increase awareness among mail recipients that mail is recyclable and

encourage them to recycle their mail through, among other actions, 

collaboration with mailing industry and other stakeholder initiatives. 

• Collaborate with parties interested in increasing the supply of paper fiber 

available for recycling. 

• Establish a special, discounted postal rate—or “Green Rate”—as a means 

of inducing mailers to adopt one or more environmentally preferable 

attributes in their mailpieces. 

• Initiate a “mail take-back” program in locations that do not have access to 

municipal paper recycling. 

Each of these opportunities appears to be consistent with (1) the agency’s 

long-standing commitment to environmental leadership and (2) the 

Postmaster General’s recent commitments to both minimize the agency’s 

impact on every aspect of the environment and to act as a positive 

environmental influence in U.S. communities. USPS would nonetheless 

need to balance those commitments, as well as the potential

environmental benefits that those opportunities might provide, against 

factors such as costs to USPS, feasibility (including logistical

considerations), and compatibility with USPS’ mission when deciding 

whether to adopt these opportunities. For example, while the costs 

associated with implementing a program for recognizing mail-related 

recycling achievements are likely to be minimal (and more than offset by 

increases in USPS’ revenues), the remaining four opportunities necessitate 

additional cost consideration. For example, two of the opportunities—

increasing awareness about mail recycling and initiating a Green Rate—

appear to have little likelihood of increasing the agency’s revenue. 

Furthermore, the remaining two opportunities—collaborating with parties 

interested in increasing the supply of paper fiber available for recycling 

and initiating a mail take-back program—may not generate sufficient 

revenues to cover their costs. Depending on the magnitude of variance 

between the expected costs and revenues, USPS may find implementing 

one or more of the opportunities unacceptable. As we recently testified, 

USPS faces multiple short- and long-term pressures in improving its 

Page 5 GAO-08-599 U.S. Postal Service
operational efficiency, increasing its revenues, and controlling its costs—

some of which are increasing faster than the overall inflation rate.8

 In 

addition, unlike in the past, USPS is now subject to an inflation-based cap

on the prices it can charge for its goods and services.9

To increase USPS’ recycling of mail-related materials and increase the 

amount of mail with environmentally preferable attributes, we 

recommend, among other actions, that the Postmaster General direct the 

Manager of Environmental Policy and Programs and other parties, as 

appropriate, to (1) require its managers at other facilities to adopt 

applicable lessons learned from its New York City recycling pilot and (2) 

assess the environmental benefits of the mail-related recycling 

opportunities identified in this report, and any others, and adopt those 

opportunities that are feasible, compatible with USPS’ mission, and 

appropriate in view of cost and other considerations. 

USPS provided its written comments on a draft of this report by letter 

dated May 2, 2008. These comments are summarized below and are 

included, in their entirety, as appendix VI to this report. USPS agreed with 

three of our four recommendations and stated that it had begun initiating 

actions to implement them. USPS also agreed, in principle, with our 

remaining recommendation to adopt applicable lessons learned from its 

New York City recycling pilot nationwide, where feasible, mission 

compatible, and appropriate in view of cost and other considerations. 

USPS stated, however, that it cannot require all of its facility managers to 

adopt these lessons since “not all lessons learned are applicable 

nationwide.” We recognize that the pilot’s lessons will not be applicable at 

every postal facility and, thus, clarified the recommendation to avoid 

confusion. 

As the primary mail carrier in the United States, USPS’ mission is to 

provide the nation with affordable and universal mail service. USPS’ 

authority was revised on December 20, 2006, with the enactment of the 

Background 

 8

 GAO, Postal Reform Law: Early Transition Is Promising, but Challenges to Successful 

Implementation Remain, GAO-08-503T (Washington, D.C.: Feb. 28, 2008).

9

 Specifically, the 2006 Postal Accountability and Enhancement Act includes an annual 

limitation on the average percentage changes in rates for each market-dominant mail 

class—such as First-Class Mail and Standard Mail—which is linked to the change in the 

Consumer Price Index for All Urban Customers. The act includes exceptions to this

inflation-based limitation, but USPS cannot raise postage rates beyond its legal authority. 

Page 6 GAO-08-599 U.S. Postal Service
Postal Accountability and Enhancement Act.10 Through this act, Congress 

provided USPS with tools and mechanisms to help ensure that USPS is 

efficient, flexible, and financially sound. The act also introduced a rate cap 

for many postal services. While Congress oversees USPS and provides 

direction to the agency on its operations and other matters, USPS receives 

only a small portion of its funding from federal appropriations.11

According to a 2001 Mailing Industry Task Force study,12 the mailing 

industry includes businesses, organizations, and other parties (mailers) 

that send and rely on mail to maintain contact with their customers. The 

mailing industry also encompasses mail preparers, including printers and 

businesses that send or receive mail on behalf of a third party. Vendors 

and suppliers of the hardware, software, and labor related to mail 

processing, such as companies who help mailers improve the accuracy of

their mailing lists, also are included in the mailing industry, according to 

this study. 

USPS offers several classes of mail, including First-Class, Standard, and 

Periodical Mail. The price for each class of mail varies, as does the level of

service that USPS provides. Mailers, including both household and 

business customers, use First-Class Mail when sending personal mail and 

personalized business correspondence, such as letters, greeting cards, 

bills, and account statements. Mailers also may use First-Class Mail to 

send advertisements and merchandise. Standard Mail is the primary mail 

class for advertisements sent in bulk quantities and cannot be used for 

sending personal correspondence, such as handwritten letters, bills, or 

account statements. Periodical Mail primarily is comprised of newspapers 

and magazines. Standard Mail rates are generally lower than First-Class 

Mail rates, in part, because USPS typically does not provide services such 

as return-to-sender and forwarding for UAA Standard Mail.13

 10 Pub. L. No. 109-435 (Dec. 20, 2006). 

11 Congress reimburses USPS for providing free or reduced postage rates to certain groups, 

such as the blind and overseas voters. For fiscal year 2008, Congress appropriated $118 

million to USPS for these purposes. 

12 The Mailing Industry Task Force, Seizing Opportunity: The Report of the 2001 Mailing 

Industry Task Force, October 2001. This task force includes chief executives of 11 leading 

mailing industry companies and the Deputy Postmaster General of USPS. 

13 While USPS generally does not forward UAA Standard Mail to the addressee, mailers can

pay USPS an additional fee to have this mail returned to them. 

Page 7 GAO-08-599 U.S. Postal Service
USPS and the mailing industry view Standard Mail as an important 

advertising medium for businesses, non-profit organizations, and other 

parties who seek to inform mail recipients about their products and 

services or to solicit contributions. While USPS currently receives about

half of its revenue from First-Class Mail, Standard Mail became the largest 

class of mail (by volume) in fiscal year 2005. During 2005, mailers spent 

about $56.6 billion on direct mail advertising—comprising about 21 

percent of all U.S. expenditures for advertising.14 USPS expects the volume 

of Standard Mail to continue to grow. 

UAA mail is mail that USPS cannot deliver to a specified address due to an 

incomplete, illegible, or incorrect address or insufficient postage, among 

other reasons. USPS’ treatment of UAA mail depends on the mail class. 

USPS forwards UAA First-Class Mail to the addressee, returns it to the 

sender, or, if the return address is missing, sends it to a USPS Mail 

Recovery Center.15 In general, USPS retains UAA Standard Mail and treats 

it as waste. Because of the large volume of UAA Standard Mail that USPS

discards annually (about 317,000 tons in 2006), USPS focuses most of its 

mail-related recycling efforts on this material. USPS also treats the mail 

discarded by recipients in postal facility lobbies (discarded lobby mail) as 

waste. While USPS does not know how much mail post office box holders 

and other recipients discard in its lobbies, a USPS official stated that the 

amount is “trivial” relative to its total volume of mail-related waste. 

USPS has reported that mixed paper (i.e., UAA mailpieces, including 

newsprint, and discarded lobby mail) accounts for up to 70 percent of its 

waste stream. According to USPS, these materials can be used to make 

everything from low-grade paper products, such as hand towels and tablet

backings, to wallboard and stock for fuel pellets that can be burned with 

coal to reduce harmful air emissions. Furthermore, according to the 

agency, the large volume of its UAA mail is an attractive and reliable 

source of clean mixed paper needed for manufacturing these and other 

products. 

 14 Direct mail refers to advertisements sent to recipients through the mail. 

15 USPS operates two First-Class Mail recovery centers in St. Paul, Minnesota, and Atlanta, 

Georgia. These facilities are responsible for the final disposition of First-Class UAA mail. 

Page 8 GAO-08-599 U.S. Postal Service
A USPS-sponsored study reported that in fiscal year 2004, UAA mail cost 

the agency more than $1.8 billion,16 which represented about 2.6 percent of

USPS’ total expenses (approximately $69 billion). About two-thirds of 

UAA mail costs resulted from forwarding mail to the intended recipients 

($422 million—23 percent) or returning it to the sender ($822 million—44 

percent). The remaining one-third of UAA mail costs are the result of 

processing waste ($270 million—15 percent), correcting addresses ($197 

million—10 percent), processing address change requests ($132 million—7 

percent), and general administration and support ($24 million—1 percent). 

Furthermore, according to USPS, creating and sending mail that cannot be 

delivered costs businesses more than $2 billion annually. 

With the exception of UAA Standard Mail, the responsibility for recycling 

discarded mail primarily lies with mail recipients. While the majority of 

mail is recyclable,17 according to the Environmental Protection Agency, 

mail recipients and others recycled only about 39 percent of the Standard

Mail they received and subsequently discarded in 2006. Studies find that 

the volume of products recycled depend on, among other matters, whether 

a recipient knows that a product is recyclable and whether the recipient 

has access to a recycling program or facility. According to one study, over 

40 percent of the public are unaware that it can recycle mail.18 Numerous 

stakeholders we interviewed confirmed this lack of recycling awareness. 

Even if individuals are aware that mail is recyclable, according to a 2005 

survey conducted by the American Forest and Paper Association, 

residents in about 31 percent of U.S. communities (14 percent of the 

population) do not have access to paper recycling programs.19 In addition, 

while a 2006 survey by the Federal Trade Commission found that only a 

small number of victims (2 percent) reported that the theft of their identify

was connected to the mail, several stakeholders told us that identity theft

 16 Christensen Associates, Volumes, Characteristics, and Costs of Processing

Undeliverable-As-Addressed Mail and Personal-Knowledge Required Mail (Madison, WI:

March 2006). 

17 In the past, some mail components, such as transparent envelope address windows and 

certain pressure-adhesive stamps, were difficult to recycle. However, according to USPS 

officials and other stakeholders, concerns about the recyclabilty of mail have generally 

been addressed.

18 The National Task Force on Greening the Mail, Recommendations of the National Task 

Force on Greening the Mail, January 1999. 

19 The communities that do not have access to paper recycling programs generally are 

located in sparsely populated, rural areas. 

Page 9 GAO-08-599 U.S. Postal Service
concerns prevent some recipients from recycling their mail. In December 

2006, we reported on efforts to increase the volume of materials recycled 

and found that, to increase recycling, U.S. municipalities need to conduct 

public education campaigns and ensure that access to recycling is both 

convenient and easy.20 Further, we identified federal policy options that 

would help municipalities increase the volume of materials recycled, 

including the establishment of (1) a nationwide education campaign to 

inform the public about recycling and (2) programs that enable consumers 

to recycle products by returning them to the manufacturer or some other 

party for recycling. These programs are known as “take-back” programs. 

USPS and the mailing industry formed a Greening the Mail Task Force in 

1996 to identify cost-effective ways to integrate environmental 

considerations into mailing practices and business processes. The task 

force issued a final report of its activities in 1999, including its efforts to 

identify “green” mail attributes (environmentally preferable attributes). 

According to the task force, environmentally preferable mail includes, 

among other attributes: 

• Mail that contains recycled paper. 

• Mail that uses certified paper. 

• Mail that is designed to use materials efficiently (such as “two-way” 

envelopes). 

• Mail that is accurately addressed for delivery.21

• Mail that is targeted to recipients who may wish to receive it.22

USPS’ Environmental Policy and Programs organization is principally 

responsible for increasing the agency’s recycling of mail-related materials 

and is the focal point for executing its environmental policy throughout 

the agency. USPS also has organizations that, among their other 

responsibilities, attempt to increase the amount of mail with 

 20 GAO, Recycling: Additional Efforts Could Increase Municipal Recycling, GAO-07-37 

(Washington, D.C.: Dec. 29, 2006). 

21 As previously discussed, USPS treats UAA Standard Mail as waste when it cannot be

delivered. 

22 We adopted these environmentally preferable attributes for our reporting purposes. 

Page 10 GAO-08-599 U.S. Postal Service
environmentally preferable attributes. For example, Address 

Management’s goal is to decrease the amount of UAA mail. To accomplish 

this, the organization provides mailers with tools to better manage the 

quality of their mailing lists while, according to USPS, striving to maximize 

its ability to efficiently deliver mail as addressed. The Product 

Development organization within Marketing helps manufacturers develop 

mail-related products that contain recycled materials. Finally, USPS’ Sales 

organization—also within Marketing—promotes the use of environmental 

preferable attributes in direct mail advertising and in USPS shipping 

materials. 

USPS and the mailing industry have undertaken numerous initiatives to 

increase the recycling of mail-related materials and increase the amount of

mail with environmentally preferable attributes. For example, USPS has 

undertaken five key mail-related recycling initiatives, including the 

establishment of annual goals to increase its recycling revenue from $7.5 

million in fiscal year 2007 to $40 million in fiscal year 2010 and a pilot 

recycling program in New York City. Representatives of the mailing 

industry and other stakeholders also have undertaken a wide range of 

initiatives to, among other actions, increase the amount of mail that is 

recycled. For example, three mailing industry associations recently 

introduced separate recycling awareness campaigns to encourage mail 

recipients to recycle their catalogs, envelopes, and magazines. In addition,

the Direct Marketing Association—whose members collectively send 

about 80 percent of all Standard Mail—is undertaking several initiatives, 

including an effort to encourage mailers to use environmentally preferable

mail attributes. 

USPS has undertaken five key initiatives to increase its recycling of mailrelated materials. Specifically, USPS recently (1) established goals for 

increasing its recycling revenue; (2) refocused its attention on 

environmental matters, including mail-related recycling, and intends to 

require recycling where cost-effective and feasible; (3) consolidated waste

management contracts to generate increased recycling revenues and 

reduce its waste disposal costs; (4) launched a pilot recycling program in 

New York City; and (5) implemented tools to track the environmental 

performance of its areas and districts. While USPS recently established 

goals for increasing its recycling revenues, inconsistencies in the way 

USPS collects data, if not resolved, will hamper efforts to measure its 

progress in meeting these goals. Furthermore, at the conclusion of our 

review, it was not clear whether, or to what extent, USPS would require its 

USPS and the Mailing 

Industry Have 

Undertaken 

Numerous MailRelated Recycling 

Initiatives 

USPS Has Undertaken Five 

Key Initiatives to Increase 

Its Recycling of MailRelated Materials

Page 11 GAO-08-599 U.S. Postal Service
managers at other facilities to adopt—where applicable, feasible, mission

compatible, and appropriate in view of cost and other considerations—

lessons learned from its New York City pilot. 

In March 2008, USPS established annual goals for increasing the $7.5 

million it generated from recycling mail-related materials in fiscal year 

2007. Specifically, USPS intends to generate $15 million in mail-related 

recycling revenue in fiscal year 2008, $30 million in fiscal year 2009, and

$40 million in fiscal year 2010. According to USPS, reaching its fiscal year

2010 goal could also reduce its solid waste disposal costs by $10 million 

annually. Thus, in fiscal year 2010, USPS could realize a full financial 

benefit of $50 million. To help reach its initial fiscal year 2008 goal, 

according to USPS officials, each of the agency’s nine geographic areas 

developed a plan to generate $2 million from recycling in fiscal year 2008.23

Longer term, according to these officials, the $40 million goal for fiscal 

year 2010 is based on the expectation that each of its 82 districts will 

generate an average of about $500,000 in recycling revenues. 

Such goals are a step in the right direction and address the need for USPS 

to generate additional revenue, which is one of the agency’s four strategic 

goals. However, by excluding savings that result from lower waste 

disposal costs, the goals do not reflect the full financial benefit attributable

to mail-related recycling. This is because when USPS facility managers 

implement mail-related recycling programs, their facilities generate less 

waste, thereby reducing the facilities’ waste disposal costs (in addition to 

generating recycling revenue). Revising the agency’s goals to include the

savings from lower waste disposal costs or adopting additional goals to 

reflect the full financial benefit of recycling would help focus USPS 

employees on the need to achieve greater cost reductions—consistent 

with a second USPS strategic goal.24 According to USPS officials, USPS is 

developing the capacity to track solid waste disposal volumes and intends 

to develop a plan for achieving its recycling goals. However, at the 

conclusion of our review, it had not agreed to revise its goals or to adopt 

additional goals for measuring its savings from lower waste disposal costs 

to reflect the full financial benefit attributable to mail-related recycling. 

USPS Established Goals for 

Increasing Its Recycling 

Revenue, but Inconsistencies in 

the Way It Collects Data, If 

Unresolved, Will Hamper 

Efforts to Measure Its Progress 

 23 For management purposes, USPS divides the country into nine geographic areas. Each 

area is comprised of districts, and there are 82 districts nationwide. 

24 USPS’ Strategic Transformation Plan 2006-2010 lists four strategic goals: generate 

additional revenue; reduce costs; achieve results with a customer-focused, performancebased culture; and improve service. 

Page 12 GAO-08-599 U.S. Postal Service
Regardless of whether USPS finds it beneficial to revise its goals to reflect 

the full financial benefit attributable to mail-related recycling, in order to 

measure its progress, USPS will need to (1) specify how it will measure its 

progress toward its goals and (2) ensure that its organizations collect and

report accurate, reliable, and consistent data, which, according to agency

officials, does not presently occur. For example, according to both USPS 

officials and our analysis of USPS documentation some district facilities 

combine recycling revenues with waste disposal costs. Additionally, our 

analysis of USPS documentation indicates that in fiscal year 2006 at least 

one large district facility combined recycling revenues with waste savings 

attributable to recycling—which, together, comprise the full financial 

benefit of recycling.25 Inconsistent reporting practices hamper efforts to 

accurately measure the agency’s progress in meeting its recycling revenue 

goals. To partially address this problem, in March 2008, the agency’s 

accounting organization sent an e-mail to USPS area managers requesting 

that they report recycling revenues separately from waste disposal costs. 

While this request addresses the need to report recycling revenue 

separately, it does not constitute a requirement for the managers at the 

area-, district-, or facility-level to do so. Furthermore, the e-mail does not 

address matters related to the reporting of USPS’ savings from lower 

waste disposal costs, or require these managers to report data on their 

savings using a consistent method. Finally, at the conclusion of our 

review, USPS had neither (1) specified how it will measure progress 

toward its goals nor (2) required its organizations to collect and report 

accurate, reliable, and consistent data. Without taking further action, 

USPS may not be able to accurately assess its progress toward meeting its 

goals—regardless of which goals it eventually adopts. 

While USPS has had a mail-related recycling program in place since the 

1990s, security concerns arising from the introduction of anthrax in the 

mail stream in 2001 caused USPS to deemphasize recycling until recently,

according to USPS officials. In December 2007, however, USPS announced 

its intention to refocus its attention on environmental matters, including 

the recycling of UAA mail and mail-related materials.26 According to USPS, 

USPS Recently Refocused Its 

Attention on Environmental 

Matters, including Mail-Related 

Recycling, and Intends to 

Require Recycling Where CostEffective and Feasible 

 25 Specifically, according to documentation supplied by USPS, in fiscal year 2006, the

Processing and Distribution Centers in Boston, Massachusetts, and Carol Stream, Illinois,

did not record waste disposal cost savings, while the Processing and Distribution Center in

Portland, Oregon, combined recycling revenues and waste disposal cost savings in a single 

figure. Similar reporting inconsistencies exist at the district- and area-levels, according to

USPS officials. 

26 December 2007 update to USPS’ Strategic Transformation Plan for 2006-2010. 

Page 13 GAO-08-599 U.S. Postal Service
recycling will help protect the value of Standard Mail as a form of 

advertising, generate additional revenues, and reduce USPS’ waste 

disposal costs. Recycling UAA mail and other mail-related materials also 

provides USPS with a means to enhance its long-standing commitment to 

environmental leadership. Furthermore, recycling these materials appears 

to be consistent with the Postmaster General’s recent commitments to 

minimize the agency’s impact on every aspect of the environment and to 

act as a positive environmental influence in U.S. communities. 

As part of its refocused attention on environmental matters, in July 2007, 

USPS issued a revised policy—termed a Management Instruction—that 

addresses its waste management issues.27 With respect to recycling, the 

policy encourages district managers and installation heads to establish 

recycling programs to collect UAA mail and discarded lobby mail in 

central locations. While the policy indicates that employees at USPS’ 

plants and post offices “should recycle” these mail-related materials, they 

are not required to do so if it is not cost-effective or logistically feasible.

For example, according to USPS officials, recycling may not be costeffective or logistically feasible at facilities that lack storage space or 

generate a limited quantity of recyclable mail-related materials.28

The July 2007 policy superseded USPS’ previous policy and guidelines, 

issued in September 1995,29 which (1) were specific to recycling mailrelated materials and (2) provided significantly more guidance on 

recycling UAA mail, discarded lobby mail, and facility paper waste. In 

addition, while not explicitly stated, the 1995 policy “technically required”

facility managers to implement mail-related recycling programs at all 

USPS facilities that generate these types of waste, according to agency 

officials. 

According to the prior policy, effective targeting of UAA mail can achieve

many objectives. For example, it “can help meet postal waste reductions 

goals and implement more efficient and environmentally sound 

 27 Integrated Waste Management, July 2007, Management Instruction EL-890-2007-5. 

28 In September 2007, USPS also published guidance for implementing the policy, including

information on how to initiate successful mail-related recycling programs at postal 

facilities entitled Implementation Guide for Managers: District Recycling Programs, 

September 2007. 

29 Recycling of Discarded Mail and Undeliverable Bulk Business Mail, September 1995, 

Management Instruction AS-550-95-14. 

Page 14 GAO-08-599 U.S. Postal Service
alternatives to solid waste disposal practices.” In addition, the 1995 policy

noted that such an “effort saves [USPS] money in solid waste disposal and 

reduces criticism that third-class [Standard Mail] mail volumes contribute 

to municipal solid waste problems.” Finally, according to the prior 1995 

policy, recycling UAA mail also enhances the viability of Standard Mail as 

an environmentally friendly advertising medium. To help USPS accomplish 

these objectives, the 1995 policy required facility managers to (1) keep 

records of revenues generated by recycling, as well as the costs and 

quantities of solid waste generated at their facilities; (2) conduct an annual 

evaluation of their practices related to discarded mixed paper, disposal 

methods, and recycling alternatives; and (3) supply information on their 

annual evaluations, including the costs, volumes, disposal methods, 

recycling alternatives, and barriers associated with implementing a mailrelated recycling program at their facilities to his or her district manager. 

The prior policy also established others responsibilities. For example, area 

managers were responsible for ensuring that facilities that generate UAA 

mail conducted the annual evaluations and for assisting district managers

in finding markets for the material. USPS’ latest policy, issued in 2007, 

does not address these and other matters. 

During the course of our work, we discussed differences between the two 

policies with USPS officials, including the requirement for an annual 

evaluation of facility practices related to discarded mixed paper. 

According to USPS officials, the omission of this requirement was 

unintended. To address this omission as well as others, the officials 

indicated that USPS would develop a new policy that will, among other 

things, (1) provide employees with specific information on how to 

implement recycling programs at their facilities, (2) require USPS facility 

managers to implement mail-related recycling initiatives unless doing so is 

not cost-effective or logistically feasible, and (3) specify requirements for 

reporting data on USPS’ mail-related recycling activities. USPS expects to

release its revised policy, as well as guidance for implementing its 

recycling program, later this year. 

To increase its recycling revenues and reduce its waste disposal costs, 

USPS began a multi-phased process to consolidate its waste disposal and 

recycling contracts at USPS facilities nationwide. In the first phase, 

completed in January 2006, USPS centralized its negotiation and 

management of all waste disposal and recycling contracts at the Memphis, 

USPS Consolidated Contracts 

to Increase Its Recycling 

Revenue and Reduce Its Waste 

Disposal Costs 

Page 15 GAO-08-599 U.S. Postal Service
Tennessee, Category Management Center (Memphis Center).30 In the 

second phase, which recently began, the Memphis employees are working 

with managers at facilities with existing waste disposal and recycling 

contracts and are attempting to convince these managers to incorporate 

their facilities within larger, regionally-based USPS waste disposal and 

recycling contracts.31 Such contract consolidations are consistent with our 

prior findings. Specifically, in 2004, we reported that consolidating 

contracts allows private-sector companies to leverage their buying power 

and identify more efficient ways to procure goods and services.32

The Memphis Center offers facility managers four types of contracts: (1) 

waste disposal only; (2) removal of recyclables only; (3) removal of waste 

and recyclables; and (4) Total Solid Waste Management contracts, which 

cover both waste disposal and recycling.33 In fiscal year 2007, the four 

types of contracts managed by the Memphis Center resulted in 

approximately $6.6 million in recycling revenues (about $6 million) and 

waste disposal cost savings (about $600,000). 

Total Solid Waste Management contracts attempt to both (1) maximize 

recycling revenues and (2) minimize waste disposal costs by using two 

methods to collect and transport mail-related recycling materials. The first 

method—“backhauling”—uses USPS’ labor and existing transportation 

network to collect and transport mail-related recyclable materials from 

local USPS facilities (e.g., post offices) to a single USPS location, such as a 

mail processing and distribution center, where the materials are 

consolidated prior to USPS’ subsequent delivery to a paper mill or other 

 30 Previously, USPS managed these contracts at the Memphis Center and three other similar 

centers located in California, Illinois, and Connecticut, according to USPS officials. 

31 According to USPS officials, managers at small facilities still can enter into separate

contracts for their facilities, if the contracts are cost-effective and valued at less than 

$2,500. 

32 GAO, Postal Service: Progress in Implementing Supply Chain Management Initiatives, 

GAO-04-540 (Washington, D.C.: May 17, 2004). 

33 USPS received a White House “Closing the Circle” award in 2007 for its use of Total Solid 

Waste Management contracts. These awards recognize outstanding federal achievements in 

a variety of environmental areas, including waste prevention, recycling, purchasing 

environmentally-preferable products, environmental management, sustainable buildings,

disposal of electronics, and reduced fuel usage. 

Page 16 GAO-08-599 U.S. Postal Service
vendor interested in purchasing the materials.34 When consolidation at a 

single USPS facility is not feasible, USPS uses a second method—“milk 

runs”—to collect its recyclable materials. Milk runs use contractors, such 

as paper brokers and other vendors, to collect recyclable materials stored 

at local USPS facilities and transport them to their destination. USPS 

officials stated that because the contractor uses its resources, including its 

labor and transportation, to collect and transport the materials, USPS must 

pay for these services—a factor that reduces both USPS’ recycling 

revenues and its savings from lower disposal costs. 

Total Solid Waste Management contracts may include a shared savings 

component with the contractor, whereby the contractor receives a portion

of USPS’ recycling revenues and savings from lower waste disposal costs. 

Cost-sharing arrangements are intended to encourage the contractor to 

implement initiatives that maximize USPS’ recycling revenues while 

minimizing its waste disposal costs. One example of such a contract is 

USPS’ contract with Rand-Whitney, which covers 457 facilities throughout 

Pennsylvania. Rand-Whitney developed a recycling program for each 

facility that, according to documentation supplied by USPS, generated 

$177,000 in recycling revenues and reduced USPS’ waste disposal costs by 

$98,000—for a total financial benefit of $275,000 from July 2006 to June 

2007. Because this contract allows Rand-Whitney to share USPS’ revenues 

and savings, Rand-Whitney received 25 percent of this total, or

approximately $69,000, during the 12-month period. 

In an attempt to demonstrate the value of mail-related recycling programs, 

USPS began a pilot program in New York City in May 2007. The goal of the 

pilot—termed “New York City SOARs!” (Saving of America’s Resources)—

is to identify opportunities to establish and expand recycling programs in 

USPS facilities throughout New York City and, based on lessons learned, 

USPS Launched a Pilot 

Recycling Program in New 

York City 

 34 For example, after a USPS vehicle is loaded with mail at a mail processing and 

distribution center and transports the mail to local USPS facilities (e.g., post offices), the 

vehicle returns to the processing and distribution center. Instead of returning empty, or 

partially empty, however, the vehicle is loaded with UAA mail and other mail-related 

recycling materials, which have been collected and stored at local USPS facilities. The use 

of backhauling as a means to transport items and materials between postal facilities is not 

new. Rather, USPS has historically used backhauling to transport other items, such as mail 

processing equipment, between facilities. 

Page 17 GAO-08-599 U.S. Postal Service
identify recycling practices that can be used in other USPS facilities.35

USPS is implementing the pilot in stages. The first stage assessed postal 

recycling activities underway in each of New York City’s five boroughs,36

using a variety of factors, such as costs to USPS, feasibility (including 

logistical considerations), and mission compatibility. The report on the 

assessment, issued in September 2007, concluded that recycling in New 

York City (1) can generate recycling revenues, (2) will substantially reduce 

USPS’ waste disposal costs, (3) will not interfere with postal operations, 

and (4) will require only a “modest incremental” effort to accomplish. 

Based on the results of the first stage, the report suggested specific 

recycling activities in each borough, including: (1) the initiation of 

backhauling recycling programs for UAA Standard Mail and mail-related 

materials in Manhattan, Brooklyn, and the Bronx, and the expansion of the 

existing backhauling program in Queens; (2) the implementation of milk 

runs for UAA Standard Mail and mail-related materials in Staten Island; (3) 

the designation of sufficient loading dock space at USPS processing and 

distribution centers in Manhattan to accommodate trailers for storing and 

transporting mail-related recycling materials; and (4) the establishment of 

recycling programs for discarded lobby mail in all five boroughs. 

According to USPS, it is optimistic that, by carefully implementing and

enhancing mail-related recycling programs throughout New York City, it 

could generate approximately $1.3 million per year in recycling revenues 

and save an additional $800,000 in waste disposal costs.37

The pilot’s second stage began in January 2008 and, in February 2008, 

according to USPS officials, the agency issued a solicitation for a contract

to provide waste disposal and recycling services to USPS facilities in four 

of New York City’s five boroughs—Brooklyn, the Bronx, Manhattan, and 

Queens. USPS expects the contract will begin in October 2008. This pilot is 

in its early stages and, at the conclusion of our review, USPS did not have

 35 New York City was chosen as the pilot site, in part, because of its complex delivery and

operational network. USPS officials stated that if a mail-related recycling program can be 

successfully implemented in New York City, similar recycling programs probably could be

implemented at postal facilities elsewhere.

36 New York City is comprised of five boroughs—Brooklyn, the Bronx, Manhattan, Staten 

Island, and Queens. References to “New York City” refer to all five boroughs, unless a 

particular borough is specified. 

37 For perspective, if New York City had generated $1.3 million in recycling revenues in 

fiscal year 2007, it would have increased USPS’ nationwide recycling revenues of $7.5 

million by approximately 17 percent that year. 

Page 18 GAO-08-599 U.S. Postal Service
a plan or timeline for, among other actions, ending the pilot program or 

issuing a final report on the pilot. Furthermore, it was not clear whether, 

or to what extent, USPS would require its managers at other facilities to 

adopt—where applicable, feasible, mission compatible, and appropriate in 

view of cost and other considerations—lessons learned from the pilot. 

USPS also has implemented tools for tracking the environmental 

performance of its areas and districts. One such tool, called an 

“environmental scorecard,” tracks and ranks the environmental 

performance of USPS’ nine geographic areas.38 In fiscal year 2007, USPS 

used the tool to collect information needed to rank each area’s 

environmental performance in 12 general areas, such as pollution 

prevention, that includes recycling.39 To measure environmental 

performance at the district level, USPS also created a budgetary line-item

for tracking each district’s recycling revenues. 

USPS plans to share the results of both its environmental evaluation tool 

and its analyses of the districts’ recycling revenues (from the budgetary 

line-item) with its postal managers. Because USPS officials believe that the 

agency’s employees are highly competitive, according to USPS officials, 

relative differences between the areas and districts are expected to foster 

competition and increase recycling revenues throughout the postal 

network. While USPS currently does not use the results of the 

environmental evaluation tool or its analyses of the districts’ recycling 

revenues for recognizing significant mail-related recycling achievements, 

according to USPS officials, USPS could choose to do so in the future. In 

the interim, according to these officials, USPS (1) is considering 

establishing a program to nominate facilities, teams, and individuals for 

environmental excellence in seven environmental categories—one of 

which includes recycling—and (2) has changed its accounting policy to 

allow districts to receive credit for the revenue each district generates 

from recycling. 

USPS Has Implemented Tools 

to Track the Environmental 

Performance of Its Areas and 

Districts 

 38 As noted previously, USPS has nine areas and 82 districts. Facility managers report to 

district managers who, in turn, report to area managers. 

39 The tool collects, among other information, data on revenues generated from recycling 

mail-related materials and other items. Such revenues include those generated from the

sale of wastepaper, twine, and dead mail. Dead mail includes UAA mail and other mailrelated materials. 

Page 19 GAO-08-599 U.S. Postal Service
To increase the amount of mail with environmentally preferable attributes,

USPS has undertaken two multi-faceted initiatives. Specifically, USPS (1) 

initiated a second Greening the Mail Task Force to, among other activities, 

promote the use of environmentally preferable attributes in mail and (2) 

established a UAA mail cost reduction goal. It also has numerous actions 

underway that may help the agency meet its UAA mail cost-reduction goal. 

Such actions include USPS’ implementation of a new mail processing 

method that identifies and redirects incorrectly addressed mail to the 

intended addressee before delivery is attempted. USPS also has taken 

other actions to increase the amount of mail with environmentally 

preferable attributes. We discuss these actions in appendix II of this 

report. 

In September 2007, USPS initiated a second Greening the Mail Task Force 

to, among other goals, increase the amount of mail with environmentally 

preferable attributes. As discussed earlier, USPS disbanded the first task 

force in 1999 after it issued a final report that, among other matters, 

identified environmentally preferable attributes associated with mail. The 

most recent task force—formed to address mail-related issues on a longterm basis—includes USPS officials, mailing industry representatives, and 

other stakeholders. The task force has five subcommittees, each with a 

different goal. Table 1 identifies each of the subcommittees’ relevant goals. 

USPS Has Undertaken Two 

Multi-Faceted Initiatives to 

Increase the Amount of 

Mail with Environmentally 

Preferable Attributes 

USPS Initiated a Second 

Task Force to Increase the 

Amount of 

Environmentally 

Preferable Attributes in 

Mail 

Page 20 GAO-08-599 U.S. Postal Service
Table 1: Relevant Goals of the Five Greening the Mail Task Force Subcommittees 

Subcommittee Relevant goalsa

Education and Awareness on 

Sustainability and Value of the Mail 

• Promote awareness that mail is

recyclable. 

• Encourage enhanced environmental mail

designs. 

• Encourage better address accuracy. 

• Provide accurate information to policy 

makers, mailers, and the press on the 

benefits of mail. 

Improving Mail Recyclability and Source

Reduction 

• Assess the recyclability of mail products. 

• Identify recycling barriers. 

• Evaluate the conditions that impact 

successful mail delivery. 

• Identify ways to reduce UAA mail. 

• Minimize the environmental impacts 

associated with mail. 

Recycling Collection of the Mail • Increase paper recycling by implementing

and supporting mail recycling initiatives in 

postal facilities, office buildings, and 

private residences. 

Life-Cycle Analysis of Mail • Provide the mailing industry’s perspective 

on the “life-cycle inventory”b of mail and, if 

possible, conduct a full “life-cycle 

analysis” of the mail.c

Standards and Certification • Facilitate the identification and creation of 

environmental sustainability standards. 

• Facilitate a certification process for the life 

cycle of mail. 

 Source: GAO analysis of Greening the Mail Task Force documentation. 

a

For the purposes of this table, we have excluded goals that are not relevant to the topics discussed 

in this report. 

b

According to USPS, a life-cycle inventory of the mail attempts to identify emissions of significant 

pollutants throughout the entire “life-cycle” of the mail, including emissions resulting from harvesting 

trees for paper; making the paper; turning the paper into mail; processing, sorting, and distributing the 

mail to consumers; and the end of the life-cycle—when the mail is eventually discarded. 

c

A life-cycle analysis is similar to a life-cycle inventory, but is more costly, complex, and 

comprehensive to perform. If the life-cycle inventory shows that mail significantly impacts the 

environment, according to USPS, a life-cycle analysis would be conducted. At the conclusion of our 

review, we were unable to ascertain how such an analysis would affect mail-related processes and 

practices. 

Page 21 GAO-08-599 U.S. Postal Service
USPS established a UAA mail cost-reduction goal in 2006 and has 

developed numerous tools that mailers can use to improve the accuracy of

their mailing lists and reduce the amount of UAA mail they send.40 More 

recently, USPS introduced two new requirements that are expected to help 

USPS meet its UAA mail cost-reduction goal. In addition, USPS has 

implemented a new mail processing method that identifies and redirects 

incorrectly addressed mail to the intended addressee before delivery is 

attempted. 

USPS Established a UAA Mail Cost-Reduction Goal 

In addition to its recent establishment of goals for increasing the revenue 

USPS generates from recycling mail-related materials, in 2006, USPS set a 

goal of reducing UAA mail by 50 percent by fiscal year 2010. In the 

summer of 2007, USPS clarified this goal, specifying that it applied to the 

cost—not the volume—of UAA mail. USPS is developing measures to 

accurately assess its progress in meeting the UAA mail cost reduction goal. 

According to USPS, its interim measures are not sufficient for this 

purpose; however, USPS officials believe that data from its May 2009

deployment of Intelligent Mail, which we discuss later in this report, will 

provide data needed to accurately measure its progress in meeting this 

goal. 

USPS’ Tools for Improving the Accuracy of Mailing Lists Reduce 

UAA Mail 

USPS has developed numerous tools that mailers can use to increase the 

amount of mail that is accurately addressed for delivery. Mail that is 

accurately addressed decreases UAA mail volume, which, in turn, 

decreases USPS’ operational and waste disposal costs. Since these address 

accuracy tools decrease USPS’ operational costs, USPS provides lower 

USPS Established a UAA Mail 

Cost Reduction Goal, and 

Actions Are Underway That 

May Help USPS Meet This Goal 

 40 The process of improving the accuracy of addresses that comprise mailing lists is often 

referred to as “address hygiene.” 

Page 22 GAO-08-599 U.S. Postal Service
postage rates (worksharing rates)41 to mailers who use them. A partial 

description of some of USPS’ address accuracy tools follows: 

• “Address Element Correction” identifies mailpieces that are potentially

UAA and corrects small errors in the addresses (e.g., the omission of a 

directional indicator such as “NW,” or errors that refer to an avenue as a 

street). 

• “Delivery Point Validation” verifies that the address on a mailpiece

exists in USPS’ database of addresses to which it delivers. 

• “National Change-of-Address LINK” allows mailers to check their 

mailing lists against USPS’ National Change-of-Address database, which 

contains updated address information for mail recipients who have filed 

change-of-address notices with USPS. 

• “Address Change Service” allows mailers to receive, for a fee, 

electronic notices that inform them when USPS cannot deliver their 

mailpieces. For First-Class Mail, these electronic notices reduce the

amount of mail USPS must return to the sender, thereby decreasing UAA 

mail and USPS’ operating costs. For Standard Mail—which USPS generally

is not obligated to return to the sender—the electronic notices (1) inform 

mailers when their Standard mailpieces are UAA and (2) provide mailers 

with the correct addressing information. This information enables 

Standard mailers to update their mailing lists with corrected addresses 

prior to their next mailing, thereby reducing future UAA mail-related costs.

USPS Introduced Two New Requirements That Are Expected to 

Reduce UAA Mail 

USPS also introduced two recent changes that, according to USPS 

officials, will reduce UAA mail and, consequently, help USPS meets its 

UAA mail cost reduction goal (i.e., a 50 percent reduction by fiscal year 

2010). First, USPS has revised its “Move Update” requirement, which 

currently obligates First-Class mailers to use at least one approved address 

 41 Worksharing rates are discounts that USPS provides to mailers who perform certain 

activities that avoid costs that USPS would otherwise incur. Worksharing activities include, 

among other things, having mailers (1) update and accurately format their addresses; (2) 

barcode and prepare mail so that it can be sorted by USPS’ automated equipment, which 

reduces manual and other handling of mail; and (3) presort mail, such as by zip code or

specific delivery location, to reduce the number of times USPS must sort the mail before

delivery to a mail recipient. 

Page 23 GAO-08-599 U.S. Postal Service
accuracy tool (such as National Change-of-Address LINK or the Address 

Change Service) to qualify for worksharing rates. In September 2007, 

USPS expanded this requirement to include mailers who send Standard 

Mail, effective November 23, 2008. Furthermore, USPS will begin requiring 

First-Class and Standard mailers to update their mailing lists—using an 

approved address accuracy tool—95 days prior to each of their mailings.42

Second, beginning in May 2009, USPS intends to require mailers to use a 

new barcode—called the “Intelligent Mail Barcode”—on their mailpieces 

to qualify for worksharing rates. According to USPS officials, the new 

barcode will allow USPS and mailers to track individual mailpieces as they 

move through the mail stream. USPS officials believe that the capability to

track mailpieces will reduce UAA mail volumes—and, potentially, USPS 

operating costs—because mailers will be able to use the barcode to 

determine which of their mailpieces cannot be delivered and correct their 

mailing lists accordingly. USPS has initiatives underway, including an 

agreement with the Bank of America, to test the effectiveness of the 

Intelligent Mail Barcode before it is fully implemented.43

USPS Has Implemented a Method to Identify and Redirect 

Improperly Addressed Mail before Delivery Is Attempted 

In September 2007, USPS also implemented a new, nationwide mail 

processing method—called the “Postal Automated Redirection System”—

that identifies and redirects mailpieces to individuals who have moved.

According to USPS, if a mail recipient has moved and filed a change-ofaddress request with USPS, the automated redirection system identifies 

mailpieces addressed to his or her prior address when these mailpieces 

first enter the mail stream and initiates one of three possible actions. The

first possible action is for USPS to immediately redirect the mailpiece to

the new, correct destination. Second, if the mailpiece is not eligible for 

forwarding or if the mailer has authorized its disposal, USPS would 

 42 Prior to the requirement’s change, First-Class mailers had to update their mailing lists 185 

days prior to each of their mailings. 

43 In December 2007, USPS’ Board of Governors approved a negotiated service agreement

between USPS and the Bank of America. The agreement—the first ever performance-based 

negotiated service agreement—requires the Bank of America to, among other actions, 

reduce its volume of UAA mail in exchange for worksharing rates. USPS has entered into 

other negotiated service agreements, but the previous agreements provided mailers with 

postage rate discounts based on (1) the volume of mail they sent and (2) the amount of

work that USPS avoided, not on reductions in the mailers’ UAA mail volumes.

Page 24 GAO-08-599 U.S. Postal Service
remove the mailpiece from the mail stream and discard it. Finally, if 

requested by the mailer, USPS would return the mailpiece to the mailer 

(i.e., the sender). In the past, USPS redirected mailpieces only after 

delivery had been attempted. In such cases, Standard Mail was returned to 

the postal facility and discarded as waste (and disposed of through 

recycling or some other means), while First-Class Mail was processed and 

forwarded, returned to the sender, or sent to a mail recovery center. 

Because USPS generally does not forward or return UAA Standard Mail—

regardless of when it is first detected—the automated redirection system 

will not reduce the amount of UAA Standard Mail that USPS must 

eventually discard. However, USPS officials believe the automated 

redirection system will reduce the cost of processing UAA mail, thereby 

contributing to the agency’s UAA mail cost-reduction goal. 

In addition to USPS’ efforts, the mailing industry and other stakeholders 

have undertaken several key initiatives to increase the volume of mailrelated materials that are recycled. Some of these initiatives were 

developed by mailing industry associations, while others are the result of 

efforts by individual mailers and organizations in the paper and 

environmental advocacy industries. For example, in 2007, the Direct 

Marketing Association (DMA), the Envelope Manufacturers Association, 

and the Magazine Publishers of America developed nationwide mail 

recycling awareness campaigns.44 While similar in nature, the three 

programs use different logos to increase recycling awareness and are 

intended for different types of mailpieces (e.g., catalogs, envelopes, and 

magazines).45 DMA members who participate in the association’s “Recycle 

Please” program are expected to include a logo in their catalogs and other 

mailpieces to encourage mail recipients to recycle their mailpieces after 

reading them. The envelope association’s program—called “Please 

Recycle”—promotes mail recycling by encouraging manufacturers to place 

The Mailing, Paper 

Recycling, and 

Environmental Advocacy 

Industries Have 

Undertaken Several Key 

Initiatives to Increase MailRelated Recycling 

 44 DMA is the main trade association for the direct mail industry. It represents, among

others, about 2,700 large mailers who send, collectively, about 80 percent of all Standard 

Mail. The Envelope Manufacturers Association represents envelope manufacturers,

includes approximately 147 organizations, and collectively produces about 80 percent of

U.S. envelopes and about 60 percent of envelopes worldwide. The Magazine Publishers of

America is the main trade association for the magazine industry and represents 

approximately 240 companies, which publish over 1,400 magazine titles. 

45 The volume of materials recycled varies for different types of mail. For example, 

according to industry stakeholders, Americans recycled about 36 percent of the catalogs

and direct mail delivered to their residences in 2005, while prior studies (pre-2006) indicate 

that about 20 percent of magazines delivered to U.S. homes were recycled. 

Page 25 GAO-08-599 U.S. Postal Service
a recycling logo on the front of envelopes and other packaging materials. 

Finally, the magazine association—which also calls its program “Please 

Recycle”—developed recycling logos and a full-page recycling 

advertisement that the association encourages its members to include in

their magazines in order to increase the volume of magazines recycled. 

Participation in these recycling awareness campaigns varies. Specifically, 

based on our calculations of data provided by officials from DMA and the 

envelope and magazine associations, as of mid-March 2008, about 2 

percent, 30 percent, and 10 percent of their members participated in these 

programs, respectively.

46 (The logos used for these recycling awareness 

campaigns are depicted in fig. 1 of app. III.) 

The second key recycling initiative involves the National Recycling 

Coalition,47 which intends to develop new recycling logos to replace the 

familiar “chasing arrows” logo currently displayed on many products. 

According to coalition representatives, one of the new logos will be 

specific to mail. The coalition believes that this logo—which has been 

used for many years—is confusing to the public. According to coalition 

officials, the logo has been repeatedly altered by product manufacturers 

and others since it was first introduced and, as a result, multiple versions 

of the logo currently exist, each of which signifies different meanings 

depending on its use.48 By updating the existing logo, the coalition hopes 

to, among other intentions, enhance consumer awareness that mail can be 

recycled. (Examples of selected “chasing arrows” recycling logos are 

depicted in fig. 2 of app. III.) 

 46 While association officials provided us with data on their members’ participation rates, 

officials from two of the three associations believe their data underestimate the extent of 

participation in their programs. For example, DMA stated that its recycling awareness 

campaign is targeted toward DMA members that market to consumers. Thus, according to

DMA, 4 percent of these members participate in the association’s “Recycle Please” 

program. In addition, DMA noted that some DMA members “operate multiple brands, so

the Recycle Please logo could be widely disseminated across many brands by a single 

parent company.” Furthermore, a magazine association official stated that at least 16 

percent of its members’ magazine titles use the “Please Recycle” logo and that these titles 

account for about 54 percent of the total number (copies) of magazines currently in 

circulation. 

47 The National Recycling Coalition is a non-profit organization that focuses on recycling

and waste prevention nationwide. 

48 The chasing arrows logo can indicate, for example, that a product is recyclable, made

from 100 percent recycled content, or made partially from recycled content. 

Page 26 GAO-08-599 U.S. Postal Service
Finally, in 2004, Time, Inc.; Verso Paper; and the National Recycling 

Coalition, among other parties, initiated the “Recycling Magazines is 

Excellent” project to inform consumers—primarily via advertisements in 

magazines—that catalogs and magazines are recyclable.49 These parties 

have piloted the project in five areas: Boston, Massachusetts; Prince 

George’s County, Maryland;50 Portland, Oregon; Milwaukee, Wisconsin; 

and New York City, New York. According to a Time, Inc., official, in 

Boston, Portland, and Prince George’s County, the program increased 

magazine recycling by 18 percent, 6 percent, and 19 percent, respectively.

Data for the Milwaukee and New York City pilots were not available at the 

conclusion of our review. 

In addition to their efforts to increase mail-related recycling, the mailing 

industry and other stakeholders have undertaken a variety of key 

initiatives to increase the amount of mail with environmentally preferable 

attributes. As described below, DMA is responsible for several of these 

initiatives. Other stakeholder initiatives, including those of individual 

mailers, environmental organizations, and other non-profit organizations 

are discussed in appendix IV of this report. 

DMA has undertaken several key initiatives to increase the amount of mail 

with environmentally preferable attributes, particularly with respect to 

improving its members’ mail targeting practices and the accuracy of their 

mailing lists. The first such effort, the Mail Preference Service,51 was 

introduced in 1971 and is a list of consumers who have requested not to 

receive (i.e., opt-out of) “prospecting mail” sent by DMA members.52 DMA 

requires its members to honor such requests and, consequently, forbids its 

members from selling or exchanging this list for any purpose other than 

The Mailing Industry and 

Other Stakeholders Have 

Undertaken Several Key 

Initiatives to Increase the 

Amount of Mail with 

Environmentally 

Preferable Attributes 

DMA Has Undertaken Several 

Key Initiatives to Increase the 

Amount of Mail with 

Environmentally Preferable 

Attributes 

 49 The logo used in the “Recycling Magazines is Excellent” project is depicted in figure 1 of

appendix III. 

50 The Prince George’s County pilot also includes the Washington, D.C., metropolitan area.

51 One of our objectives is to report on the recent key initiatives undertaken by USPS, the 

mailing industry, and other stakeholders. While the Mail Preference Service is not new, we 

discuss it in this report because, historically, it was the main tool available to mail 

recipients who wanted to decrease the amount of unwanted mail they receive. 

52 “Prospecting mail” is advertising mail that mailers send to mail recipients in an attempt to

establish a business relationship (i.e., future business) with them. 

Page 27 GAO-08-599 U.S. Postal Service
removing prospective customers from their mailing lists.53 According to 

DMA officials, by eliminating prospecting mail, the Service (1) reduces the

amount of mail a consumer receives by approximately 80 percent and (2) 

prevented 930 million pieces of unwanted mail from entering the mail 

stream in 2007.54 While DMA officials stated that the association works 

with consumer advocacy groups and other parties to inform consumers 

about the Mail Preference Service,55 a recent study conducted by Pitney 

Bowes indicates that two-thirds of Americans are not aware of the 

Service’s existence. In part to address this lack of awareness, several 

parties within the environmental advocacy industry recently implemented 

other opt-out programs. As noted previously, these programs are 

discussed in appendix IV of this report. 

More recently, DMA formed the Committee on Environment and Social 

Responsibility, which is comprised of 16 executives from DMA’s member 

organizations. Formed in 2005, the committee’s goals are to identify 

challenges that direct marketers face with respect to “social 

responsibility” issues, such as environmental sustainability and corporate 

citizenship issues, and to develop guidance to address these challenges. 

The committee designed and executed a survey to benchmark the 

environmental practices of its members and developed a Web-based tool 

to help members evaluate their environmental practices in five areas: (1) 

paper procurement and use, (2) address quality (accuracy) and data 

management, (3) design, (4) packaging and printing, and (5) recycling and

 53 Consumer requests to opt-out of receiving prospecting mail do not affect DMA member 

mailings to consumers when the member has already established a business relationship 

with the customer. Instead, these mailings will continue. Additionally, DMA members that 

have pre-existing relationships with consumers who have registered with the Mail 

Preference Service can continue to exchange these consumers’ personal information with 

other companies for marketing purposes. 

54 Until recently, DMA charged consumers a $1 fee, payable by credit card or check, to sign 

up for the Mail Preference Service—regardless of how the consumer signed up for the 

service. The $1 fee still applies to opt-out requests sent through the mail. However, DMA

eliminated this fee in January 2008 for internet-based requests. While a valid credit card 

number is still required for authentication purposes, according to a DMA official, the 

association is testing different methods to authenticate consumer opt-out requests and no 

longer requires a credit card number for non-catalog internet-based requests. 

55 A similar DMA service—the Deceased Do Not Contact List—enables family members to

permanently remove a deceased individual from prospect mailing lists. The Deceased Do 

Not Contact list was created in response to concerns that mail addressed to deceased

individuals (1) poses a risk of identity theft—particularly when the mailpiece contains 

sensitive information, such as an unsolicited credit card offer—and (2) distresses grieving 

family members. 

Page 28 GAO-08-599 U.S. Postal Service
pollution reduction. The tool also enables mailers to create an 

environmental vision statement or policy statement for, among other 

purposes, displaying on their Web sites. DMA officials could not supply 

data on the extent to which its members use this tool. 

In 2007, DMA also passed the “Resolution Asserting Environmental 

Leadership in the Direct Marketing Community.” The resolution calls on 

DMA members—by June 2008—to voluntarily establish internal 

measurements and benchmarks for assessing their business practices with 

respect to a list of 15 environmentally preferable practices. This list—

called the “Green 15”—aligns with mailer business activities, such as paper 

procurement and use, mailing list accuracy, and mailpiece design. While 

the adoption of the 15 environmentally preferable practices is generally

voluntary, in June 2008, DMA intends to establish goals and timetables for 

measuring its members’ success in implementing these practices, which,

according to DMA officials, could lead to future DMA requirements.56 DMA 

officials stated that, thus far, members generally have reacted positively to

the list of 15 preferable practices, although some members have expressed 

concerns about purchasing recycled and certified paper. Specifically, 

members expressed concerns that (1) the supply of these products may 

not be sufficient to meet demand if DMA were to require its members to 

use them; and (2) due to the number of forest certification programs and 

the controversy over the programs’ various merits, it is not clear which 

program they should use.57 (For more information on the Green 15, see 

app. V of this report.) 

Finally, in October 2007, DMA launched its “Commitment to Consumer 

Choice” program. Under this program, DMA members must, among other 

actions, include—on every direct mail solicitation they send—an option 

for consumers to opt-out of receiving future direct mail solicitations from 

 56 To encourage members to adopt the 15 environmentally preferable practices, DMA 

developed a “Green 15 Toolkit,” which contains, among other matters: (1) information on 

paper recycling, paper procurement, and the environmental impact of mail; (2) guidance on

how members should benchmark their progress toward adopting environmentally 

preferable practices; (3) strategies to improve address accuracy and reduce UAA and

unwanted mail; and (4) a “paper pledge” template that members can use to develop a paper 

procurement policy that considers environmentally preferable practices. 

57 According to DMA officials, DMA intends to educate and encourage its members to use 

recycled and certified paper whenever feasible, but does not intend to specify which 

certification program its members should use. Instead, DMA specifies a list of available 

forest certification programs and allows its members to choose the program or programs 

that best suits their needs. 

Page 29 GAO-08-599 U.S. Postal Service
that member, regardless of whether the member has previously 

established a business relationship with those customers.58 The new 

requirement, effective in October 2009, will strengthen DMA members’ 

current obligation to provide mail recipients with one opt-out notice per 

year. The Commitment to Consumer Choice program also includes several

other requirements related to consumer choice. Some of these 

requirements are new or modified, while others are long-standing.59 For 

example, DMA members must (1) disclose, upon consumer request, the 

source from which they obtained data about the consumer; (2) eliminate,

upon consumer request, the transfer or rental of the consumer’s personal 

information to other marketers; (3) increase the frequency with which 

they update their mailing lists against information in DMA’s Mail 

Preference Service opt-out database (from a quarterly to a monthly basis); 

and (4) act on all customer opt-out requests within 30 days and for a 

period of at least 3 years.60

According to DMA officials, DMA has an internal process for ensuring that

members comply with its requirements.61 The process begins with DMA’s 

Corporate Responsibility group, which receives all customer complaints 

regarding the receipt of unwanted mail.62 If a pattern of complaints about a 

 58 In other words, if a consumer contacts a company and asks to be removed from its future 

mailings, that consumer will no longer receive any mailpieces from the company. Should 

the consumer later place an order for a product with that company, the consumer will 

receive the product and any correspondence related to it (e.g., invoices and bills), but—

under the terms of the program—would not receive other direct mail solicitations from the 

company. 

59 Currently, members must comply with all of the program’s requirements, except for the 

provision that every mail piece contain an option to opt-out of future direct mail 

solicitations from that member. DMA officials stated that the Association has delayed 

enforcement of this requirement to allow sufficient time for its members to redesign and 

test their mailpieces. 

60 The Commitment to Consumer Choice program also allows DMA members to provide

customers with a “frequency opt-out” option. When available, such an option would allow 

mail recipients to specify the frequency with which they wish to receive future mailings,

such as catalogs, from a DMA member without opting out of all mailings from the member. 

61 Although DMA’s process for ensuring that its members comply with its requirements also

is not a recent initiative, we nonetheless describe it to convey the method by which DMA 

officials said the association enforces its member requirements. 

62 According to DMA officials, the association also randomly selects about 200 of its

members annually for monitoring using a “secret shopper” program. According to these 

officials, the monitoring program helps to ensure that DMA members are complying with 

the association’s requirements. 

Page 30 GAO-08-599 U.S. Postal Service
company emerges, DMA officials stated that the group would file a formal 

case before DMA’s Committee on Ethical Business Practices.63 If the 

offending mailer still refuses to comply with DMA requirements, DMA’s 

Board of Directors can, among other actions, expel the mailer from the 

association. According to DMA officials, however, member expulsions are 

rare. The officials explained that the association’s goal is self-correction, 

not punishment, and that mailers normally alter their practices to avoid 

expulsion from DMA. 

USPS, mailing industry, and other stakeholders we spoke to identified five 

opportunities that USPS could choose to undertake to increase its 

recycling of mail-related materials and to encourage mailers to increase 

the amount of mail with environmentally preferable attributes.64 The five

opportunities cited most frequently were for USPS to (1) implement a 

program for recognizing mail-related recycling achievements; (2) increase 

awareness among mail recipients that mail is recyclable and encourage 

them to recycle their mail through, among other actions, collaboration 

with mailing industry and other stakeholder initiatives; (3) collaborate 

with parties interested in increasing the supply of paper fiber available for

recycling; (4) establish a special, discounted postal rate—or Green Rate—

as a means of inducing mailers to adopt one or more environmentally 

preferable attributes in their mailpieces; and (5) initiate a mail take-back 

program in locations that do not have access to municipal paper recycling. 

Each of these opportunities appears to be consistent with (1) the agency’s 

long-standing commitment to environmental leadership and (2) the 

Postmaster General’s recent commitments to both minimize the agency’s 

impact on every aspect of the environment and to act as a positive 

environmental influence in U.S. communities. Based on our analysis, 

however, USPS would need to assess factors such as costs to USPS; 

feasibility, including logistical considerations; and mission compatibility in 

deciding whether to adopt the opportunities. 

Stakeholders Cited 

Five USPS MailRelated Recycling 

Opportunities, but 

USPS Would Need to 

Assess Several 

Factors in Deciding 

Whether to Adopt 

Them 

 63 According to a DMA official, the Committee on Ethical Business Practices is comprised 

of approximately 15 DMA members, who meet once per month to resolve consumer 

complaints against DMA mailers. 

64 As discussed in appendix I, we reported on those opportunities that stakeholders cited 

more than twice and that were not currently being addressed by an ongoing USPS 

initiative. 

Page 31 GAO-08-599 U.S. Postal Service
The stakeholders we interviewed identified five opportunities that USPS 

could chose to undertake to increase its recycling of mail-related materials 

or to encourage mailers to increase the amount of mail with 

environmentally preferable attributes. First, several stakeholders stated 

that USPS could increase its mail-related recycling activities by offering 

recognition, financial awards, promotional opportunities, and other 

incentives to reward exemplary USPS recycling achievements. Three 

USPS officials stated that such incentives could target facility-level 

managers and employees, who are likely to be critical to the successful 

implementation of mail-related recycling programs. As discussed, USPS is 

considering establishing a program to nominate facilities, teams, and 

individuals for environmental excellence. As currently envisioned, the 

program would honor excellence in seven environmental categories, 

including “pollution prevention.” While USPS is contemplating recognition 

for “improvements in recycling processes or programs” as part of its 

achievements related to pollution prevention, the program under 

consideration does not specifically recognize mail-related recycling 

achievements. An incentives program targeted specifically toward such 

achievements could foster greater competition throughout USPS, resulting 

in substantial increases in the agency’s recycling revenue and significant

savings in its waste disposal costs. Such a program could be based solely 

on recycling revenues, or include other metrics—such as the amount 

(tonnage) of materials recycled or its savings in waste disposal costs. 

Second, because mail recipients often are unaware that mail can be 

recycled, stakeholders suggested that USPS conduct a campaign to 

increase awareness among mail recipients that mail is recyclable and to 

encourage them to recycle their mail. Such a campaign could be 

collaborative in nature, unilateral, or undertaken through some 

combination of outreach efforts. For example, several stakeholders stated 

that USPS could collaborate with one or more of the ongoing mailing 

industry and other stakeholder initiatives to increase recycling awareness 

among mail recipients and to encourage them to recycle.

65 Such an effort, 

among other matters, could (1) address common misconceptions related 

to the recyclability of various types of mail and (2) raise awareness about 

the primary causes of identity theft—two reasons why recipients may not 

Stakeholders Identified 

Five USPS Opportunities 

 65 As discussed previously, these initiatives include DMA’s “Recycle Please” program, the 

magazine and envelope associations’ “Please Recycle” programs, the National Recycling 

Coalition’s development of a recycling logo specific to mail, and the “Recycling Magazines

is Excellent” program initiated by the National Recycling Coalition; Time, Inc.; and Verso 

Paper. 

Page 32 GAO-08-599 U.S. Postal Service
recycle their mail. In addition, USPS could collaborate with members of 

the Greening the Mail Task Force to design and implement a plan to 

increase the public’s awareness in these and other areas.66 If USPS desired 

to do so, stakeholders suggested that the agency also could take unilateral

action to promote mail recycling by, for example, delivering an

informational post card or some other form of communication to each 

address in America. Such an approach would be similar to USPS’ actions

to promote its various products and services nationwide, which, according 

to USPS officials, typically increase consumer awareness by nearly 30

percent. Stakeholders also suggested that USPS develop postmarks and 

stamps and install signage in postal lobbies to promote mail recycling. 

Third, numerous stakeholders suggested that USPS collaborate with 

parties, such as the American Forest and Paper Association and U.S. paper 

recycling companies, to increase the supply of fiber needed for 

manufacturing recycled paper products. According to these stakeholders,

such fiber is typically in short supply domestically because it is usually 

exported to countries, such as China and India, which pay premium prices 

for the fiber. The stakeholders added that the constant supply of UAA mail 

available through USPS could be used to increase the domestic supply of

recycled fiber. Such a supply increase could potentially decrease the cost 

of using recycled paper products which, in turn, could encourage their 

increased use.67 One way for USPS to undertake this opportunity is to 

collaborate with the American Forest and Paper Association, which, 

according to association representatives, is eager to increase mail-related 

recycling.68 Such a collaboration, they said, would contribute to the 

association’s goal of recovering (i.e., preventing landfill disposal or 

incineration) 55 percent of paper consumed in the United States by 2012. 

In addition, USPS could collaborate with members of its Greening the Mail 

Task Force to design and implement a plan to increase the supply of paper 

 66 As noted previously, one of the Task Force’s five subcommittees—the subcommittee on 

“Education and Awareness on Sustainability and Value of the Mail”—intends to, among 

other goals, promote awareness that mail is recyclable. 

67 Many mailers told us that using recycled paper is more expensive than using virgin paper

(i.e., paper made from unrecycled fiber harvested directly from forests) for their mailings.

68 According to USPS officials, the agency recently invited representatives of the American 

Forest and Paper Association to participate on the Greening the Mail Task Force. 

Page 33 GAO-08-599 U.S. Postal Service
fiber available for recycling.69 USPS also could choose to explore, or 

expand, partnerships with local recyclers. One paper recycling company in

New Jersey, for example, purchases and transports UAA mail from USPS 

facilities in Maryland, Pennsylvania, New Jersey, and elsewhere to 

manufacture recycled paper products, such as paper towels, toilet paper, 

facial tissue, and napkins. According to a company representative, 

because UAA mail is a critical feedstock for the company’s production 

methods, the company would like to increase its supply of UAA mail as 

long as the cost of transporting UAA mail to the company does not 

become prohibitive. 

Fourth, numerous stakeholders in the environmental advocacy industry, 

suggested that USPS establish a special, discounted postal rate—or Green 

Rate—as a means of inducing mailers to adopt one or more 

environmentally preferable attributes in their mailpieces. According to 

these parties, for example, USPS could establish a special discount for 

mailers that use recycled and/or certified paper. Such a discount, they 

said, would help mailers offset the increased costs associated with using 

recycled paper and would provide an incentive for mailers to use certified

paper.70 A Green Rate also could reward mailers who, among other 

practices, (1) use certain targeted marketing strategies, (2) can

demonstrate measurable reductions in the amount of UAA mail they send,

and (3) use mail materials efficiently. With respect to targeted marketing 

strategies, for example, a Green Rate could reward mailers who 

voluntarily participate in mail opt-out programs—such as the program 

offered by Catalog Choice71—and can demonstrate that they honor mail 

 69 As previously noted, one of the Task Force’s five subcommittees—the subcommittee on 

“Recycling Collection of the Mail”—intends to, among other goals, increase mail recycling 

by implementing and supporting mail recycling initiatives in postal facilities, office 

buildings, and private residences. 

70 As previously described, certified paper is produced from forests that are managed 

according to a variety of environmentally preferable practices. The two major forest

certification programs in the U.S. are the Sustainable Forestry Initiative® and the Forest

Stewardship Council. The Sustainable Forestry Initiative®—formerly a part of the 

American Forest & Paper Association—is now an independent organization managed by 

the Sustainable Forestry Initiative, Inc. The logos for these certification programs are 

depicted in figure 1 of appendix III. 

71 As previously discussed, mail opt-out programs enable mail recipients to decline to 

receive certain mail solicitations, such as credit card offers and catalogs, from direct mail 

marketing companies. One such program is Catalog Choice, which is a free service that 

allows mail recipients to opt-out of unwanted catalogs that they currently receive. For 

more information on Catalog Choice, see appendix IV. 

Page 34 GAO-08-599 U.S. Postal Service
recipients’ requests to be removed from their mailing listings.72 A Green 

Rate also could reward mailers who, over time, reduce the amount of UAA 

mail they send. Beginning in May 2009, USPS intends to use its Intelligent 

Mail Barcodes to establish large mailers’ UAA mail rates (the baseline) 

and, over time, measure changes in the frequency of the mailers’ UAA 

mail. While large mailers will be required to use the barcodes to receive 

worksharing rates for their mailings, USPS also could choose to use these 

data to reward mailers who meet a specified target for UAA mail 

reductions. In addition, if USPS chose to do so, it could reward mailers 

according to a “sliding scale,” whereby mailers would receive larger 

discounts for greater UAA mail reductions.73 A final example of practices 

that could be considered for a Green Rate is the use of two-way reusable 

envelopes and other mailpieces that use materials efficiently.

Finally, numerous stakeholders suggested that USPS, using its existing 

transportation network, initiate a mail take-back program to facilitate the 

recycling of discarded and unwanted mail in rural, sparsely populated 

areas that do not have access to municipal paper recycling.

74 While the 

details of such a program would need to be developed, stakeholders 

suggested that USPS—possibly, in collaboration with others—could 

supply mail recipients in these locations with pre-addressed packages to 

send their discarded mail either directly to a plant for recycling or, 

indirectly, to other facilities—including, possibly, USPS facilities—where 

the packages could be held for subsequent pick up and recycling. 

Conceptually, such a program resembles several existing take-back 

programs for used products—such as inkjet cartridges, digital cameras, 

and cellular phones—whereby the program sponsor (e.g., a manufacturer) 

supplies the consumer with a pre-paid and pre-addressed envelope for 

returning used products through the U.S. mail. Stakeholders noted that 

USPS receives revenue for returning the products under the existing takeback programs and, depending on how such a program is funded, also 

could receive revenue under a take-back program for mail. 

 72 As discussed, DMA allows mail recipients to opt-out of receiving certain mailings from its 

members. Because DMA members are required to honor those requests, it seems unlikely 

that such actions would qualify for a special postal discount. Therefore, if USPS were to

develop a Green Rate related to the mailers’ participation in opt-out programs, it would 

likely focus on programs in which mailer participation is voluntary. 

73 The current performance-based Negotiated Service Agreement with Bank of America is

structured in a similar fashion. 

74 According to a 2005 survey conducted by the American Forest and Paper Association, 14

percent of the population (31 percent of U.S. communities) reside in these areas. 

Page 35 GAO-08-599 U.S. Postal Service
Each of the five stakeholder-identified opportunities appears to be 

consistent with (1) the agency’s long-standing commitment to 

environmental leadership and (2) the Postmaster General’s recently

expressed commitment to minimize USPS’ impact on every aspect of the 

environment and to act as a positive environmental influence in U.S. 

communities. However, based on our analysis, USPS would need to assess

factors such as cost; feasibility, including logistical considerations; and 

mission compatibility in deciding whether to adopt the opportunities. 

Each of the five opportunities has overall cost considerations given their 

likely impact on staff and other resources that would be needed to, among 

other actions, develop plans, procedures, and agreements for 

implementing them. USPS also would need to identify the staff and offices

responsible for successfully initiating and carrying out the opportunities, 

and provide training as appropriate. In addition, while the costs associated 

with implementing a program for recognizing mail-related recycling 

achievements are likely to be minimal (and more than offset by increases 

in USPS’ revenues), the remaining four opportunities necessitate 

additional cost consideration. For example, two of the opportunities—

increasing awareness about mail recycling and initiating a Green Rate—

appear to have little likelihood of increasing the agency’s revenue. 

Furthermore, the remaining two opportunities—collaborating with parties 

interested in increasing the supply of paper fiber available for recycling 

and initiating a mail take-back program—may not generate sufficient 

revenues to cover their costs. Depending on the magnitude of variance 

between the expected costs and revenues, USPS may find implementing 

one or more of the opportunities unacceptable. This is, in part, because as

we recently testified, USPS faces multiple short- and long-term pressures 

in improving its operational efficiency, increasing its revenues, and 

controlling its costs—some of which are increasing faster than the overall

inflation rate.

75 In addition, unlike in the past, USPS is now subject to an

inflation-based cap on the prices it can charge for its goods and services. 

Specifically, the 2006 Postal Accountability and Enhancement Act includes

an annual limitation on the average percentage changes in rates for each 

market-dominant mail class—such as First-Class Mail and Standard Mail—

USPS Would Need to 

Assess Several Factors in 

Deciding Whether to Adopt 

the Opportunities 

Cost Considerations 

 75 GAO, Postal Reform Law: Early Transition is Promising, but Challenges to Successful 

Implementation Remain, GAO-08-503T (Washington, D.C.: Feb. 28, 2008).

Page 36 GAO-08-599 U.S. Postal Service
which is linked to the change in the Consumer Price Index for All Urban 

Customers.76

In addition to these overall cost considerations, three of the five 

opportunities have additional cost-related factors that USPS would need to

assess prior to deciding whether to adopt them.77 First, while the cost of 

collaborating with other entities to increase recycling awareness among 

mail recipients and to encourage mail recipients to recycle their mail could 

be minimal, according to a USPS official, each of its recent nationwide 

promotional campaigns (which do not involve collaboration) cost USPS 

approximately $2.1 million. Such costs, however, may be overstated with 

respect to a recycling campaign because USPS could choose, in

collaboration with others, to target only mail recipients in zip codes that 

do not have access to municipal paper recycling (about 14 percent of the 

U.S. population). Furthermore, USPS could elect to “piggyback” a 

recycling awareness message on another of its promotional mailings, 

which, by itself, would result in little additional cost. However, according 

to USPS officials, such a promotional campaign would necessitate the use 

of recycled paper to remain consistent with the agency’s recycling 

awareness message. As previously stated, using recycled paper is more 

expensive than using virgin paper and, thus, would increase the cost of 

such a campaign. 

Second, because establishing a special discount to induce mailers to adopt 

more environmentally preferable business practices would—absent other 

actions—reduce USPS revenues,78 USPS would have to assess the overall

affects of such a discount on its financial position. In addition, USPS 

would need to assess the specific cost implications associated with each 

environmentally preferable attribute it chooses to include in a Green Rate. 

For example, if USPS were to consider allowing mailers who, among other 

 76 The Act includes exceptions to this inflation-based limitation, but USPS cannot raise 

postage rates beyond its legal authority. 

77 We did not identify any additional cost considerations related to two of the five 

opportunities—implementing an incentives program and collaborating with others to

increase the supply of paper fiber needed for recycling. 

78 Generally speaking, if USPS chose to implement a Green Rate, its net revenues would 

decrease by the amount of the discount multiplied by the number of mailpieces that were 

mailed using the discount. Although the lower cost for postage could cause some mailers

to increase the number of mailpieces they send, we believe that such an increase would be

marginal and that it likely would not offset the lost revenues to USPS caused by a Green

Rate. 

Page 37 GAO-08-599 U.S. Postal Service
attributes, use certain mail targeting strategies to qualify for a Green Rate 

(e.g., participation in voluntary opt-out programs), USPS would need to 

assess whether, and to what extent, doing so would reduce its revenues. 

USPS also would need to assess the costs associated with, among other of

its activities, defining a Green Rate (i.e., determining which 

environmentally preferable attributes mailers must use to qualify for the 

discount) and, to avoid potential abuse, ensuring that the mailpieces 

presented by mailers as “green” actually qualify for the discount. 

Finally, initiating a mail take-back program in locations that do not have 

access to municipal paper recycling could greatly increase USPS’ costs 

and workload. The extent of these increases would depend on a variety of

factors, including (1) the volume of additional mail generated by the 

program; (2) the characteristics, including the dimensions and weight, of 

the take-back packages that would require processing and delivery; (3) 

whether the packages would need to be manually processed;79 (4) the 

frequency with which each package needs to be handled; and (5) the 

distance the packages need to be transported.80 First, depending on the 

rate of program participation, the volume of mail requiring USPS 

processing and delivery could increase substantially. In addition, because 

the intent of such a program is for a mail recipient to combine all of the 

mail they discard during a given time frame into a single package, the

package would greatly exceed the weight of typical mailpieces received by 

the recipient.

81 Furthermore, because communities that do not have access 

to paper recycling are typically in rural, sparsely populated areas, the 

increased volume of larger and heavier mailpieces probably would travel 

long distances before reaching their final destination, thereby increasing 

USPS’ transportation costs throughout the journey. The volume, weight, 

and size of these packages also could overwhelm USPS’ service capacity in 

certain rural locations. Rural postal delivery service is typically carried out

by USPS letter carriers using privately-owned vehicles that may not be 

capable of accommodating the increased volume, weight, and size of the 

 79 Manual mail processing is far more costly than processing mail on USPS’ automated 

equipment. 

80 This distance includes both the mileage between (1) the mail recipient’s residence and 

the recipient’s local post office (i.e., the locations where the package presumably would be 

picked up and initially delivered) and (2) the local post office and the location of the

package’s destination. 

81 Additional take-back packages would be needed if the amount of discarded mail 

exceeded the capacity of a single package. The additional packages also would be heavier 

than those of typical mailpieces. 

Page 38 GAO-08-599 U.S. Postal Service
take-back packages.82 Thus, USPS may incur costs for additional vehicles 

or changes in its operational arrangements with its rural postal carriers. 

Finally, the packages mailed by recipients would not be presorted and, 

depending on how the program is implemented, may not be barcoded—

two factors that would require more costly, manual processing before 

delivery. 

Four of the five stakeholder-identified opportunities also have issues 

related to their feasibility, which USPS would need to assess prior to their 

adoption.83 For example, if USPS chose to implement a program for 

recognizing mail-related recycling achievements, such as an incentive 

program for facility-level managers and employees, it would first need to 

collect the data needed to do so. The two existing sources for USPS 

recycling data—the agency’s evaluation tool for its areas and the 

budgetary line-item for its districts—do not include facility-level data. 

Furthermore, collecting this data may not be feasible due to staffing 

constraints and the large number (about 37,000, according to USPS) of 

postal facilities nationwide. In light of this feasibility limitation, however, 

and given USPS’ goal of earning $40 million in recycling revenue in fiscal 

year 2010 from its districts’ efforts (approximately $500,000 per district), 

the agency could, instead, focus on recognizing the significant 

achievements of its district managers and employees. A district-level

incentives program, however, has its own feasibility constraints. For 

example, to help ensure equity in such an incentives program, USPS would 

need to resolve several factors related to the program’s successful 

implementation. Specifically, USPS likely would need to make

adjustments for large, regional variations in the price paid for recyclable 

mail-related materials.84 If USPS did not consider these variations, an 

incentives program based solely on revenue generated from mail-related 

recycling would seriously disadvantage certain districts. One possibility 

for resolving this issue may be to structure an incentives program on other 

Feasibility Considerations 

 82 As noted previously, such packages likely would be picked up at the mail recipient’s

address during the U.S. letter carriers’ normal mail deliveries. 

83 We did not identify any factors related to the feasibility of increasing recycling awareness 

among mail recipients. 

84 For example, according to USPS documentation, a Processing and Distribution Center in

Portland, Oregon, sold its UAA mail for $25 per ton in fiscal year 2006, whereas the 

Southeastern Pennsylvania Processing and Distribution Center was able to sell the same 

material for $105 per ton. 

Page 39 GAO-08-599 U.S. Postal Service
metrics, such as the total tonnage of material recycled or a district’s 

savings in waste disposal costs, either in lieu of, or addition to, recycling 

revenues. However, such an action would introduce other issues related to 

the opportunity’s feasibility because, according to USPS officials, USPS 

does not currently require its organizations, including its districts, to (1) 

report their recycling tonnage or savings from waste disposal costs85 or (2) 

collect and report their recycling data using consistent methods.86 The 

Manager of USPS’ Environmental Policy and Programs organization told 

us that the agency intends to require its area managers to report 

information on their recycling tonnage, in addition to their recycling

revenue and waste disposal costs, but at the conclusion of our review, 

USPS had not required these managers to do so. 

Second, if USPS chose to coordinate with parties, such as domestic 

recyclers, to increase the supply of fiber available for paper recycling, it 

would need to resolve a multitude of logistical considerations. For 

example, (1) Where will USPS store its mail-related materials for 

recycling? (2) Is sufficient storage available within USPS facilities? (3) 

Who will load the materials for delivery to the recycler? (4) Who will be 

responsible for transporting the materials and how will the deliveries be 

accomplished? and (5) Given space constraints, how often will the 

materials need to be transported, and to whom? Furthermore, to the 

extent that USPS facilities, vehicles, and other materials (e.g., crates and 

moveable carts) are used, the agency would need, among other actions, to 

develop a method for sharing its costs with recyclers and others who 

benefit directly from its efforts. If USPS were to undertake this

opportunity with a goal of recycling domestically—as recommended by 

some stakeholders—USPS may also wish to explore arrangements to 

recoup a portion of any reduction in its revenues attributable to using 

domestic recyclers. If USPS did not use its staff or if sufficient and capable 

staff is not available to undertake these and other efforts, USPS could hire 

 85 According to USPS documentation, in fiscal year 2006, three (Albany, New York; 

Southeastern Pennsylvania; and Carol Stream, Illinois) of the nine Processing and 

Distribution Centers USPS surveyed do not collect information on the amount of materials 

(tonnage) they recycle and two (Boston, Massachusetts; and Carol Stream, Illinois) do not 

collect data on savings from avoided waste disposal costs. 

86 As discussed, according to both USPS officials and our analysis of USPS documentation

some district facilities combine recycling revenues with waste disposal costs. Additionally,

our analysis of USPS documentation indicates that in fiscal year 2006, at least one large

district facility combined recycling revenues with waste savings attributable to recycling, 

which, together, comprise the full financial benefit of recycling. Similar reporting 

inconsistencies exist at the District and Area levels, according to USPS officials.

Page 40 GAO-08-599 U.S. Postal Service
a third party to identify locations where this opportunity may be feasible 

to implement and, in such cases, act as USPS’ intermediary in addressing 

these and other logistical considerations.87

Similarly, if USPS chose to establish a Green Rate, the agency would need

to resolve a wide range of issues related to the feasibility of doing so. For 

example, USPS would need to assess whether a discount for mailpieces 

with certain environmental attributes is the appropriate mechanism for 

promoting environmentally preferable business practices. If USPS were to 

proceed, it would need to define the parameters of the discount and, to 

avoid abuse, determine how it would ensure that mail presented as “green” 

actually qualifies for the discount. Several stakeholders expressed 

particular concern about the feasibility of enforcing a Green Rate, 

indicating that such a task would be administratively difficult and, 

possibly, impossible to accomplish. Finally, to determine whether a Green 

Rate is feasible, USPS would need to (1) assess the impact of such a 

discount on its net revenues and existing postal rates; (2) determine 

whether, and to what extent, a Green Rate would affect its marketdominate products, which are subject to an annual inflation-based price 

cap; and (3) if the establishment of the discount resulted in the need to

raise postal rates, evaluate whether USPS would be able to raise rates in 

accordance with the requirements in Postal Accountability and 

Enhancement Act. 

Finally, to initiate a mail take-back program, USPS would need to consider 

the logistics and overall feasibility of collecting and transporting the 

increased volumes of larger and heavier mailpieces through the mail 

stream. USPS, probably in collaboration with others, also would need to 

determine how the program would work—which likely would be a 

complex arrangement. For example, what classes of mail would the 

program cover? Who would supply the packages and postage needed to 

return the discarded mail? How would the appropriate postage be 

determined? Furthermore, where would the packages be sent, and to how 

many locations? In addition, to estimate its costs, USPS would need to 

develop, among other factors, a method for estimating (1) the number of 

mail recipients who would participate in the program and (2) the volume, 

size, and weight of their discarded mail take-back packages. While these 

 87 In New Jersey, for example, Rand Whitney serves as an intermediary between a paperrecycling company and 457 USPS facilities in Pennsylvania and, in return for its services, 

receives 25 percent of the full financial benefit generated under its contract. 

Page 41 GAO-08-599 U.S. Postal Service
considerations are numerous, the most serious question with respect to 

the program’s feasibility is “Who will pay the substantial costs associated 

with implementing the program?” 

USPS has three options to cover the costs of a mail take-back program. 

First, USPS could explore increases in its postage rates for the applicable 

classes of mail—an action that mailing industry stakeholders would likely 

strongly oppose. Furthermore, it may not be feasible to raise these rates 

because of a limitation specified in the Postal Accountability and 

Enhancement Act. Second, while USPS could require mail recipients to 

pay the postage needed to cover the program’s costs, such an action, in

our view, would greatly diminish or eliminate public participation. As we 

reported in 2006, one key to increasing the volume of materials recycled is 

to offer financial incentives to increase recycling. Thus, a mail take-back 

program that departs from this premise is, in our view, unlikely to 

succeed. Finally, USPS could solicit funding from other parties, such as 

communities, federal and non-profit organizations, businesses, 

environmental organizations, Congress, and other interested parties. While 

USPS could explore this option, it is unclear whether other parties would 

find it in their best interest to fund such a program.88

While each of these opportunities appears to be consistent with the 

agency’s environmental commitments, including the Postmaster General’s 

recent commitments to both minimize the agency’s impact on every aspect 

of the environment and to act as a positive environmental influence in U.S. 

communities, it is unclear to what extent USPS views actions to fulfill 

these commitments as being compatible with its mission and strategic 

goals. Similarly, it is not clear whether, or to what extent, USPS would be 

willing to sacrifice revenue and/or incur additional costs to further its 

environmental commitments. 

In addition, two of the five stakeholder-identified opportunities—the 

establishment of a mail take-back program and a Green Rate for 

mailpieces that incorporate a variety of environmentally preferable 

attributes—would necessitate additional cost considerations. First, several 

mailing industry stakeholders told us that they strongly oppose a Green 

Mission Compatibility 

Considerations 

 88 While a mail take-back program is similar conceptually to several existing take-back 

programs for other used products (e.g., inkjet cartridges, digital cameras, and cellular

phones), the critical difference is that for these programs, another party (not USPS) pays 

all of the costs—an action that the party presumably views as beneficial to its self-interest.

Page 42 GAO-08-599 U.S. Postal Service
Rate, in part, because of mission compatibility concerns. According to 

these stakeholders, unlike worksharing rates that reward mailers for 

reducing USPS’ costs, a Green Rate discount does not align with USPS’ 

primary mission of delivering the mail. In addition, they said that market 

forces and mailer preferences—not the establishment of a Green Rate—

should determine whether mailers choose to include environmentally 

preferable attributes in their mailpieces. Depending on how USPS chose to 

define a Green Rate, some specific aspects of the definition could cause 

additional mission compatibility concerns. For example, if the use of 

certified paper was included in a Green Rate, USPS lacks the expertise 

needed to evaluate the relative merits of the various—and controversial—

certification programs.89 Likewise, if a Green Rate incorporated certain 

targeted marketing strategies, USPS could be drawn into a contentious 

debate about the relative merits of various opt-out programs, including 

voluntary programs administered by Catalog Choice and others.90

Finally, as discussed previously, establishing a mail take-back program 

likely would result in significant increases in the volume, size, and weight 

of packages moving through the mail stream. Such increases could 

overburden USPS’ delivery networks and create delivery delays. Related to

this, several stakeholders from USPS and the mailing industry told us that 

USPS’ mission is to deliver the mail in a timely fashion—not to help mail

recipients recycle their discarded and unwanted mail. 

USPS, the mailing industry, and others have developed a wide range of 

initiatives that, over time, could alleviate some concerns related to the 

perceived negative impact of mail on the environment. Several of the 

initiatives also have the potential to improve USPS’ financial position—

while also enhancing its environmental reputation in U.S. communities. 

However, it is not clear what level of trade-offs, including decreased 

revenue and/or increased costs, USPS would find acceptable to incur to 

further its commitments and reputation on environmental matters. 

Conclusions 

 89 Evaluating the relative merits of the various certification programs likely would require

expertise in environmental principles and practices associated with managing forests.

90 For example, DMA recently advised its members not to accept opt-out requests

originating from Catalog Choice and other (non-DMA) programs. Appendix IV provides

additional information on this matter. 

Page 43 GAO-08-599 U.S. Postal Service
While much is being done, USPS has numerous opportunities to enhance 

its mail-related recycling efforts. For example, while establishing goals 

should assist USPS in generating substantial additional mail-related 

recycling revenues, the agency has not established similar goals for 

reducing its costs associated with waste disposal. Consequently, its 

recycling goals do not reflect the full financial benefit attributable to mailrelated recycling. In our view, revising USPS’ recycling goals to include 

savings from lower waste disposal costs or adopting additional goals that 

reflect the full financial benefit attributable to mail-related recycling would 

help focus USPS employees on the need to achieve greater cost 

reductions—consistent with one of USPS’ strategic goals. Related to this,

while USPS intends to develop a plan to help it achieve its recycling goals, 

it is not clear whether this plan will (1) specify how progress toward its 

goals will be measured or (2) ensure that the data USPS will use to 

measure its progress are accurate, reliable, and collected using a 

consistent method. Furthermore, while USPS launched a pilot recycling 

program in New York City to, among other objectives, apply lessons 

learned to other postal facilities, it is unclear whether, and to what extent, 

USPS will require its facility managers to adopt these lessons where 

applicable, feasible, mission compatible, and appropriate in view of cost 

and other considerations. Finally, while these considerations are also 

applicable to the adoption of the five stakeholder-identified opportunities 

discussed in this report, each opportunity, at a minimum, provides 

thoughts and insights on activities that USPS might find—after careful 

analysis—beneficial to adopt. 

To increase USPS’ recycling of mail-related materials and increase the 

amount of mail with environmentally preferable attributes, we recommend 

that the Postmaster General direct the Manager of Environmental Policy

and Programs and other parties, as appropriate, to take the following four 

actions: 

Recommendations for 

Executive Action 

• Revise the agency’s recycling goals to include savings from lower waste 

disposal costs or adopt additional goals that would reflect the full financial 

benefit attributable to mail-related recycling. 

• Ensure that the mail-related recycling plan it develops specifies, among 

other matters, how USPS will (1) measure progress toward its goals and 

(2) ensure that the data it uses for these measurements are accurate, 

reliable, and collected using a consistent method. 

Page 44 GAO-08-599 U.S. Postal Service
• After completion of the New York City pilot, require facility managers at other 

facilities to adopt lessons learned, where applicable, feasible, mission

compatible, and appropriate in view of cost and other considerations. 

• Assess the environmental benefits of the mail-related recycling 

opportunities identified by stakeholders in this report, and any others, and 

adopt those opportunities that are feasible, compatible with USPS’ 

mission, and appropriate in view of cost and other considerations. 

USPS provided its written comments on a draft of this report by letter dated 

May 2, 2008. These comments are summarized below and are included, in

their entirety, as appendix VI to this report. USPS agreed with three of our 

four recommendations and stated that it had begun initiating actions to 

implement them. USPS also agreed, in principle, with our remaining 

recommendation to adopt applicable lessons learned from its New York City 

recycling pilot nationwide, where feasible, mission compatible, and 

appropriate in view of cost and other considerations. USPS stated, however,

that it cannot require all of its facility managers to adopt these lessons since 

“not all lessons learned are applicable nationwide.” We recognize that the 

pilot’s lessons will not be applicable at every postal facility and, thus, clarified

the recommendation to avoid confusion. 

We are sending this report to the congressional requestors and their staffs. 

We are also sending copies to the Postmaster General and other interested

parties. We will make copies available to others upon request. In addition, 

the report will be available at no charge on the GAO Web site at 

http://www.gao.gov. 

If you or your staffs have any questions regarding this report, please 

contact me at siggerudk@gao.gov or by telephone at (202) 512-2834. 

Contact points for our Office of Congressional Relations and Public Affairs 

may be found on the last page of this report. GAO staff that made key 

contributions to this report are listed in appendix VII. 

Katherine A. Siggerud 

Director, Physical Infrastructure Issues

Agency Comments 

and Our Evaluation 

Page 45 GAO-08-599 U.S. Postal Service
List of Congressional Committees

The Honorable Joseph I. Lieberman 

Chairman 

The Honorable Susan M. Collins 

Ranking Member 

Committee on Homeland Security and Governmental Affairs 

United States Senate 

The Honorable Thomas R. Carper 

Chairman 

The Honorable Tom Coburn, M.D. 

Ranking Member 

Subcommittee on Federal Financial Management, Government 

 Information, Federal Services, and International Security 

Committee on Homeland Security and Governmental Affairs 

United States Senate 

The Honorable Henry A. Waxman 

Chairman 

The Honorable Tom Davis 

Ranking Member 

Committee on Oversight and Government Reform 

House of Representatives 

The Honorable Danny K. Davis 

Chairman 

The Honorable Kenny Marchant 

Ranking Member 

Subcommittee on Federal Workforce, Postal Service, 

 and the District of Columbia 

Committee on Oversight and Government Reform 

House of Representatives 

Page 46 GAO-08-599 U.S. Postal Service
Appendix I: Objectives, Scope, and 

Methodology 

Page 47 GAO-08-599 U.S. Postal Service

Appendix I: Objectives, Scope, and 

Methodology 

Our objectives were to (1) describe the key, recent recycling 

accomplishments (initiatives) of USPS,1

 the mailing industry, and other 

stakeholders and (2) identify additional recycling opportunities that USPS 

could choose to engage in (or influence mailers to undertake), including 

the factors that USPS would need to assess prior to adopting the 

opportunities. Such factors include costs to USPS; feasibility, such as 

logistical considerations; and compatibility with USPS’ mission. 

To address our overall reporting objectives, we interviewed a wide range 

of USPS officials as well as representatives from about 40 organizations 

(stakeholders) that have expertise in mail and paper recycling issues. For 

expertise in mail, we contacted numerous, major mailing industry 

associations which encompass the three major classes of mail that contain 

advertisements—First-Class, Standard, and Periodical. For expertise on 

environmental matters, we contacted organizations with positions on a 

wide range of environmental matters, including the waste generated from

mail. For expertise in paper recycling issues, we contacted organizations 

that, among other matters, have an interest in increasing the amount of 

paper fiber available for recycling. During our interviews, we requested 

contact information for other relevant stakeholders and, as appropriate, 

contacted representatives from those organizations who agreed to speak 

with us.2

 The stakeholders we interviewed are listed in table 2.

 1

 Because many of USPS’ mail-related recycling efforts are in the early stages of their 

implementation, we discuss these efforts as “initiatives,” rather than as “accomplishments.” 

2

 Despite several attempts, we were unable to obtain interviews with representatives from 

numerous organizations including the American Bankers Association; the American 

Catalog Mailers Association; the Center for a New American Dream; the Mailing & 

Fulfillment Service Association; the Major Mailers Association; the National Association of

Presort Mailers; the Printing Industries of America; and the U.S. Conference of Mayors. 
Appendix I: Objectives, Scope, and 

Methodology 

Table 2: Stakeholders Interviewed 

Catalog Choice The Forest Stewardship Council 

Conservatree The Fulfillment Management Association 

Co-op America The Greeting Card Association 

EcoEnvelopes The Institute for Local Self-Reliance 

Environmental Defense The Magazine Publishers of America 

Forest Ethics The Mail Moves America Coalition 

GreenDimes The Mailers Council 

McDonough Braungart Design Chemistry The National Newspaper Association 

National Envelope The National Postal Policy Council 

Norm Thompson Outfitters The National Recycling Coalition 

Pitney Bowes, Inc. The National Solid Wastes Management 

Association 

Rand Whitney Recycling The National Wildlife Federation 

RR Donnelley The Newspaper Association of America 

The Alliance of Non-Profit Mailers The 100% Recycled Paperboard Alliance 

The American Forest and Paper 

Association 

The Saturation Mailers Coalition 

The Association for Postal Commerce Time, Inc 

The Bank of America Corporation United States Environmental Protection 

Agency 

The Direct Marketing Association United States Office of the Federal 

Environmental Executive 

The Direct Marketing Association Nonprofit 

Federation 

United States Postal Service

The Envelope Manufacturers Association Weyerhaeuser

Source: GAO.

In addition, to describe recent USPS initiatives, we (1) reviewed and 

analyzed relevant documents related to the initiatives; (2) toured various 

facilities engaged in recycling activities, including USPS facilities in 

Baltimore and Philadelphia, a paper recycling facility and a printing 

facility; and (3) attended meetings of the “Greening the Mail Task Force”—

a committee of USPS, mailing industry, and other stakeholders whose 

mission is to identify and address environmental issues that relate to the 

mail. We also interviewed a wide range of officials in various USPS 

organizations, including Environmental Policy and Programs, Address 

Management, Product Development, Pricing and Classification, Marketing, 

Government Affairs, the Office of Inspector General, and the Memphis 

Category Management Center. In addition, we interviewed USPS staff 

Page 48 GAO-08-599 U.S. Postal Service
Appendix I: Objectives, Scope, and 

Methodology 

involved in implementing the New York City pilot; facility managers and 

employees involved with recycling in Baltimore and Philadelphia facilities; 

and employees involved with the National Postal Forum and the Mailers’ 

Technical Advisory Committee, among others. To determine recent 

initiatives of the mailing industry and others, we interviewed each of the 

stakeholder organizations listed above and reviewed and analyzed relevant 

documents related to the initiatives they identified. We selected key,

recent initiatives undertaken by USPS, the mailing industry, and others 

based on our professional judgment.

To identify additional mail-related recycling opportunities that USPS could 

choose to undertake, we solicited the views of representatives from the 

aforementioned stakeholders. We specifically inquired about opportunities 

to increase the recycling of mail and the amount of mail with 

environmentally preferable attributes.3

 We reported on those opportunities 

that stakeholders cited more than twice and that were not currently being 

addressed by an ongoing USPS initiative. Finally, using our professional 

judgment, we analyzed pertinent factors, such as cost; feasibility, including

logistical considerations; and compatibility with USPS’ mission, that USPS 

would need to assess prior to adopting the opportunities. 

We discussed First-Class, Standard, and Periodical Mail with stakeholders;

however, we primarily focused on Standard Mail because of (1) its 

increasing prominence in the mail stream; (2) its contribution to the 

municipal solid waste stream; (3) USPS’ responsibility for discarding large 

volumes of UAA Standard Mail; and (4) the issues critics cite related to 

Standard Mail, which are reflected in numerous “Do Not Mail” state 

legislative initiatives and a recent online petition for a national Do Not 

Mail Registry. While other studies measure the environmental impact of 

mail using different measurements (e.g., the carbon footprint attributable 

to mail),4

 this report focuses on the role recycling plays in eliminating mail 

and mail-related materials from municipal solid waste, decreasing USPS’ 

 3

 As described previously, these attributes include mail that (1) contains paper from 

recycled paper fiber (recycled paper); (2) uses paper from responsibly-managed forests 

(certified paper); (3) is designed to use materials efficiently, such as reusable “two-way” 

envelopes; (4) is accurately addressed for delivery; and (5) is targeted to mail recipients 

who may wish to receive it. 

4

 For example, USPS issued a study in 2007 that concluded that advertising mail has a 

positive overall environmental impact, in part, because it reduces the number of shopping 

trips consumers would otherwise make to purchase products. 

Page 49 GAO-08-599 U.S. Postal Service
Appendix I: Objectives, Scope, and 

Methodology 

waste disposal costs, increasing USPS’ revenue, and enhancing USPS’ 

commitment to environmental leadership. 

We conducted this performance audit from April 2007 to June 2008 in 

accordance with generally accepted government auditing standards. Those 

standards require that we plan and perform the audit to obtain sufficient, 

appropriate evidence to provide a reasonable basis for our findings and 

conclusions based on our audit objectives. We believe that the evidence 

obtained provides a reasonable basis for our findings and conclusions 

based on our audit objectives. 

Page 50 GAO-08-599 U.S. Postal Service
Appendix II: Other USPS Actions to Increase 

the Amount of Mail with Environmentally

Preferable Attributes 

Page 51 GAO-08-599 U.S. Postal Service

Appendix II: Other USPS Actions to Increase 

the Amount of Mail with Environmentally 

Preferable Attributes 

In addition to the two multi-faceted initiatives discussed in the body of this

report, USPS also has undertaken other actions to increase the amount of

mail with environmentally preferable attributes. First, according to USPS 

officials, the agency uses 100 percent recycled paperboard in its Priority 

Mail and Express Mail packages and envelopes.1

 In addition, these officials 

stated that the agency’s marketing materials, such as postcards and 

brochures, typically contain at least 10 percent recycled paper. Finally,

USPS recently approved a change in its mailing standards which allows 

mailers to use reusable mailpieces, such as “two-way” envelopes. Such 

envelopes enable mail recipients to either remove or cover the recipient’s 

address in order to reveal a return address.2

 Mailers that use two-way 

envelopes do not need to include a return envelope in their mailpieces, 

which reduces their paper use and costs. 

 1

 USPS received a “Cradle to Cradle” certification from a consulting firm in 2007 for its 

Priority Mail and Express Mail packages and envelopes. The consulting firm—which helps

clients create “ecologically intelligent products”—awards these certifications to parties 

that demonstrate an understanding of their products’ environmental impact.

2

 USPS officials stated that reusable mailpieces are not frequently used because mail 

recipients often inadvertently destroy the return mechanism when they first open the 

envelope. In addition, according to a USPS marketing official, USPS typically does not

encourage customers to reuse its Priority Mail or Express Mail packaging and envelopes 

because doing so likely would decrease the image of these items and detract from USPS’ 

brand name. 
Appendix III: D

Rel

epiction of Various Mailated Recycling Logos 

Page 52 GAO-08-599 U.S. Postal Service

Appendix III: Depiction of Various MailRelated Recycling Logos 

Figure 1: Mail-Related Recycling Logos

Recycling Magazines is

Excellent (collaboration 

between Verso Paper, Time 

Inc., and the National 

Recycling Coalition)

Direct Marketing

Association

Magazine Publishers of America

Envelope Manufacturers Association

Sustainable Forestry Initiative® program

Sources: The Direct Marketing Association; Envelope Manufacturers Association; Magazine Publishers of America; Verso Paper, Time 

Inc., and the National Recycling Coalition; Sustainable Forestry Initiative, Inc.; Forest Stewardship Council. 

Forest Stewardship Council
Appendix III: Depiction of Various MailRelated Recycling Logos 

Figure 2: Logos Indicating Paper Products Contain Recycled Materials or Are 

Recyclable 

Product Contains Recycled Materials Product is Recyclable

Source: National Recycling Coalition.

Note: These logos appear on many products, including mail, but are not specific to mail. 

Page 53 GAO-08-599 U.S. Postal Service
Appendix IV: Other Stakeholder Initiatives to

Increase the Amount of Mail with 

Environmentally Preferable Attributes 

Page 54 GAO-08-599 U.S. Postal Service

Appendix IV: Other Stakeholder Initiatives to 

Increase the Amount of Mail with 

Environmentally Preferable Attributes 

While several initiatives have been taken by the Direct Marketing Association 

(DMA), other stakeholders in the mailing industry and environmental

advocacy organizations also have initiatives underway to increase the amount 

of mail with environmentally preferable attributes. For example, the National

Postal Forum—a non-profit educational corporation—sponsors an annual 

postal event and trade show with the same name. This forum, among other

goals, provides USPS and mailing industry attendees with training, education,

and opportunities to communicate with USPS officials on matters related to

the mail. In 2007, the forum included a series of workshops designed to 

educate mailers on USPS’ tools for improving the accuracy of their mailing

lists and reducing UAA mail volumes. The May 2008 forum featured more

workshops on improving the accuracy of mailing lists, including a series of

“Xtremely Green” workshops to address the environmental implications of

the mail and ways to effectively communicate to mail recipients about 

environmental issues. 

A second stakeholder, the Mailers’ Technical Advisory Committee, (1) 

shares technical information on matters of mutual interest related to mailrelated products and services and (2) discusses ways to enhance the value 

of these products and services.1

 The committee recently published two 

reports. The first report, issued in 2006, contained a list of best practices 

for accurately addressing mailpieces and recommended, among other 

matters, that mailers—prior to each mailing—update their mailing lists by

using USPS’ tools for improving address accuracy. We were unable to 

ascertain the extent to which mailers have adopted the report’s 

recommendations. The second report, issued in 2007, (1) outlined a system 

by which USPS could certify the accuracy of mailing lists purchased by 

mailers and (2) described several scenarios in which such a system would 

reduce UAA mail. According to USPS, it intends to develop a list 

certification system by October 1, 2010. However, this time frame is 

contingent on the deployment of software upgrades related to its postal 

automated redirection system and the mailing industry’s implementation 

of Intelligent Mail barcodes, expected in May 2009. 

Third, several parties within the environmental advocacy industry have 

undertaken initiatives to decrease the amount of unwanted mail received 

by mail recipients. For example, “41 Pounds” and “GreenDimes”—a nonprofit and for-profit organization, respectively—were established in 2006

 1

 The committee is comprised of USPS officials, over 50 mailer associations, and a small 

number of other organizations in the mailing industry.
Appendix IV: Other Stakeholder Initiatives to

Increase the Amount of Mail with 

Environmentally Preferable Attributes 

to help mail recipients decline (i.e., opt-out of) many types of unwanted 

mail, including credit card and sweepstakes offers, insurance promotions, 

coupon booklets, and catalogs. These organizations accomplish this goal 

by, among other activities, (1) helping mail recipients register for DMA’s 

Mail Preference Service and (2) directly contacting non-DMA mailers—

who are not required to use this service—to request them not to send mail 

solicitations to these mail recipients. 41 Pounds charges $41 for its 

services and, according to its Web site, donates one-third of this fee to 

community and environmental organizations. GreenDimes charges $20 for 

its services and, as of mid-March 2008, planted five trees for its services 

and an additional tree for every catalog that a member (mail recipient) 

declined (up to five additional trees). In addition, Catalog Choice—a nonprofit program sponsored by the Ecology Center and endorsed by the 

National Wildlife Federation and the Natural Resources Defense Council—

offers a free service that allows consumers to stop receiving unwanted 

catalogs. Consumers can search for catalogs on the Catalog Choice Web

site and, after providing their address information, opt-out of those they do

not wish to receive.

2

 According to the organization’s Web site, nearly 

700,000 people had registered for its service, opting out of over 9 million 

catalogs as of March 31, 2008.3

Fourth, some parties within the envelope industry also have undertaken 

initiatives to increase the amount of mail with environmentally preferable 

attributes. For example, one major envelope manufacturer enables its 

customers to customize their envelopes with an assortment of 

environmentally preferable attributes, including recycled and certified 

paper. A company official estimated that 80 percent of his company’s 

 2

 The Catalog Choice Web site includes links to hundreds of catalog company Web sites. 

Catalog Choice also plans to offer consumers the opportunity to “opt in” to catalogs they 

wish to receive. 

3

 The introduction of services offered by organizations such as 41 Pounds, GreenDimes, 

and Catalog Choice has been contentious. In late 2007, the Direct Marketing Association 

met with its members and advised them not to accept opt-out requests provided by these 

and other organizations unless they meet certain authentication and privacy requirements.

According to DMA officials, the advice was offered, in part, to address concerns about 

whether opt-out requests submitted through these organizations truly originated from a

mail recipient. DMA officials explained that, several years ago, one company registered its 

entire mailing list with DMA’s Mail Preference Service, with the objective of ensuring that

its customers would not receive mail from other direct marketers. A Catalog Choice official 

explained that his organization also has measures in place to detect fraudulent opt-out 

requests. Additionally, the official said that although DMA’s Service offers consumers the 

opportunity to opt-out of catalogs, he believes the service provided by Catalog Choice is 

easier to use. 

Page 55 GAO-08-599 U.S. Postal Service
Appendix IV: Other Stakeholder Initiatives to

Increase the Amount of Mail with 

Environmentally Preferable Attributes 

envelope sales include at least one environmentally preferable attribute. 

Another company designed reusable “two-way” envelopes that are made 

with at least 30 percent recycled paper. 

Fifth, some individual catalog mailers have undertaken their own efforts to 

incorporate environmentally preferable attributes in their mailpieces. In 

2007, Forest Ethics—an environmental non-profit organization that, 

among other activities, encourages catalog companies to improve their 

environmental practices—surveyed the catalog industry and reported that

nine major catalog mailers had attained its highest environmental rating 

by, among other actions, reducing the quantity of paper they use and using 

certified and recycled paper. Another catalog mailer partnered with 

Environmental Defense in 2001 and began using paper with 10 percent 

recycled paper. This company also offers mail recipients a “frequency optout” option that enables mail recipients to choose how often they wish to 

receive the company’s catalog. 

Finally, to increase the prevalence of environmentally preferable attributes

in magazines, a non-profit organization called Co-op America created the 

“Magazine PAPER Project.”4

 The project helps magazines change their 

business practices to better protect the environment by, among other 

actions, educating magazine publishers about the environmental 

consequences associated with the paper they use and working with 

publishers to help them adopt environmentally preferable practices, such 

as the use of recycled or certified paper.5

 A representative of Co-op 

America estimated that the percentage of magazines using recycled paper 

is extremely low.6

 According to the representative, convincing magazine 

officials to use recycled or certified paper is difficult, due, in part, to (1) 

confusion regarding the environmental benefits of using these products, 

(2) the higher cost of recycled paper, (3) the availability of recycled paper, 

and (4) the perception among many magazine companies that using 

recycled paper will adversely affect the appearance of their products. 

 4

 According to its Web site, Co-op America’s mission is to harness economic power—the

strength of consumers, investors, businesses, and the marketplace—to create a socially 

just and environmentally sustainable society. 

5

 While there are several forest certification programs, the Magazine PAPER Project only

supports paper certified by the Forest Stewardship Council. 

6

 Specifically, out of approximately 18,000 distinct magazine titles in the United States, the

official estimated that less than 1 percent use recycled paper. His estimate is likely to 

understate the percentage of magazines that use recycled paper, however, because some 

magazines have low circulation rates and, consequently, are not known to Co-op America. 

Page 56 GAO-08-599 U.S. Postal Service
Appendix V: DMA’s List of 15

Environmentally Preferable 

Business Practices 

Page 57 GAO-08-599 U.S. Postal Service

Appendix V: DMA’s List of 15 

Environmentally Preferable Business 

Practices 

As discussed in the body of this report, DMA developed a list of 15 

environmentally preferable business practices—the “Green 15.” While

adoption of these 15 practices is mostly voluntary, in June 2008, DMA intends 

to establish goals and timetables for measuring its members’ success in

implementing these practices, which, according to DMA officials, could lead

to future DMA requirements. Overall, the Green 15 consists of five mailer 

business practices: paper procurement and use, mailing list accuracy and data

management, mail design and production, packaging, and recycling and 

pollution reduction. A description of the specific practices related to each of

the five overall business practices follows: 

Paper procurement and use – Mailers should: 

1. Encourage paper suppliers to increase their wood purchases from 

recognized forest certification programs; 

2. Require paper suppliers to commit to implementing sustainable 

forestry practices that (a) protect forest ecosystems and biodiversity 

and (b) provide wood and paper products that meet industry needs; 

3. Ask paper suppliers where their paper comes from before purchasing 

it, with the intent of avoiding paper from unsustainable or illegally 

managed forests; 

4. Require paper suppliers to document that they do not produce or sell 

paper from illegally harvested or stolen wood; and 

5. Evaluate the paper used for advertising, product packaging, and 

internal consumption in order to identify opportunities to increase 

their environmentally preferable attributes. 

Mailing list accuracy and data management – Mailers should: 

6. Comply with DMA guidelines for list management,1

 such as: 

a. maintaining lists of consumers who do not wish to receive their 

mail solicitations; 

b. updating their mailing lists against the Mail Preference Service 

database; 

 1

 DMA requires its members to comply with its list management guidelines. Currently, this

is the only required component of the Green 15. 
Appendix V: DMA’s List of 15 

Environmentally Preferable 

Business Practices 

c. including—on every direct mail solicitation they send—an option 

for mail recipients to opt-out of receiving all direct mail 

solicitations from that member, regardless of whether a business 

relationship has been previously established; 

7. Use tools developed by USPS or other parties to improve the accuracy

of their mailing lists; and 

8. Apply predictive targeted marketing models to reduce unwanted mail, 

where appropriate.2

Mail design and production – Mailers should: 

9. Review their direct mail solicitations and other printed marketing 

material to determine whether, for example, smaller or lighter designs 

(that use less paper) are appropriate; and 

10. Test and use production methods that reduce waste. 

Packaging – Mailers should: 

11. Encourage their packaging suppliers to submit price quotes for 

environmentally preferable packaging alternatives, in addition to 

approved or existing packaging specifications. 

Recycling and pollution reduction – Mailers should: 

12. Purchase office paper and packaging materials that are made from 

recycled paper, where appropriate; 

13. Integrate the use of electronic communications (e.g., e-mail, internet, 

and intranet) for both internal and external communications; 

14. Ensure that all environmental labeling is clear, honest, and complete; 

and 

15. Participate in DMA’s “Recycle Please” campaign and/or other recycling 

campaigns in order to demonstrate that their company or organization 

has a program to encourage recycling. 

 2

 Predictive targeted models use customer data such as age, gender, and purchase history 

to forecast customer purchasing behaviors. 

Page 58 GAO-08-599 U.S. Postal Service
Appendix VI: Comments from USPS 

Page 59 GAO-08-599 U.S. Postal Service

Appendix VI: Comments from USPS 
Appendix VI: Comments from USPS 

Page 60 GAO-08-599 U.S. Postal Service
Page 61 GAO-08-599 U.S. Postal Service

Appendix VII: GAO Contact and Staff 

Acknowledgments 

GAO Contacts Katherine A. Siggerud (202) 512-2834 or siggerudk@gao.gov

In addition to the individual named above, Kathleen Turner, Assistant 

Director; Samer Abbas; Kathleen Gilhooly; Jeff Jensen; Joshua Ormond; 

Daniel Paepke; Stephanie Purcell; and Erin Roosa made key contributions 

to this report. 

Staff 

Acknowledgments 

(542117) 
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