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MAIL `.\‘L ADDRESS LABELS,

GOVERNMENT M

Storage

KANSAS STA

28 HEARING

BEFORE THE

SUBCOMMITTEE ON

N TAL FACILITIES AND MAIL

OF THE

== COMMITTEE ON

FFICE AND CIVIL SERVICE

iE OF REPRESENTATIVES

NINETY-SECOND CONGRESS

SECOND SESSION

ON

H.R. 8659

A BILL TO AMEND TITLE 39, UNITED STATES CODE, AS

ENACTED BY THE POSTAL REORGANIZATION ACT, TO

REQUIRE THAT THE MAIL LABEL OR OTHER COVER OF

ANY PUBLICATION HAVING PERIODICAL PUBLICATION

MAIL PRIVILEGES, WHEN MAILED TO A SUBSCRIBER,

SHALL BEAR READILY INTELLIGIBLE INFORMATION

REGARDING THE NAME AND ADDRESS OF THE SUBSCRIBER AND THE EXPIRATION DATE OF THE CURRENT

SUBSCRIPTION, AND FOR OTHER PURPOSES

FEBRUARY 24, 1972

Serial No. 92-34

Printed for the use of the

Committee on Post Office and Civil Service

U.S. GOVERNMENT 

•PRINTING OFFICE

75-0910 WASHINGTON : 1972
COMMITTEE ON POST OFFICE AND CIVIL SERVICE

THAL)DEUS J. DULSKI, New York, Chairman

DAVID N. HENDERSON, North Carolina, Vice Chairman

MORRIS K. UDALL, Arizona

DOMINICK V. DANIELS, New Jersey

ROBERT N. C. NIX, Pennsylvania

JAMES M. HANLEY, New York

CHARLES H. WILSON, California

JEROME R. WALDIE, California

RICHARD C. WHITE, Texas

WILLIAM D. FORD, Michigan

LEE H. HAMILTON, Indiana

FRANK J. BRASCO, New York

GRAHAM PURCELL, Texas

BILL CHAPPELL, JR., Florida

H. R. GROSS, Iowa

EDWARD J. DERWINSKI, Illinois

ALBERT W. JOHNSON, Pennsylvania

WILLIAM LLOYD SCOTT, Virginia

JAMES A. McCLURE, Idaho

LAWRENCE J. HOGAN, Maryland

JOHN H. ROUSSELOT, California

ELWOOD HILLIS, Indiana

WALTER E. POWELL, Ohio

WILLIAM 0. MILLS, Maryland

RICHARD W. MALLARY, Vermont

JOHN H. MARTINY, Chief Counsel

VINCENT M. GAUGHAN, Staff Director and Special Counsel

B. BENTON BRAY, Associate Staff Director

VicToR C. SMIROLDO, COUn8e/

WILLIAM A. IRVINE, Assistant Staff Director

THEODORE J. KAZY, Senior Staff Assistant

FRANCIS C. FORTUNE, Coordinator

ROBERT E. LocKHART, Assistant Counsel

SUBCOMMITTEE ON POSTAL FACILITIES AND MAIL

ROBERT N. C. NIX, Pennsylvania, Chairman

GRAHAM PURCELL, Texas

DAVID N. HENDERSON, North Carolina

JAMES M. HANLEY, New York

JAMES A. MeCLURE, Idaho

ALBERT W. JOHNSON, Pennsylvania

RICHARD W. MALLARY, Vermont

Ex Officio Voting Members

THADDEUS J. DULSKI, New York H. R. GROSS, Iowa

THOMAS R. KENNEDY, Staff Assistant, Room B-345(b), Rayburn Building—Ext. 56741

(II)
CONTENTS

Statement of— Page

Dulski, Hon. Thaddeus J., a Representative in Congress from the

State of New York 1

Sharp, Darwin E., manager, Mail Classification Division, U.S. Postal

Service 7

Williams, Raymond E., area consultant for the Virginia State Library

on behalf of the American Library Association 12

Communications from—

McLain, Marvin L., legislative director, American Farm Bureau Federation, letter dated February 23, 1972 21

Owen, Stephen F., Jr., Counihan, Casey & Loomis Law Offices, letter

dated March 10, 1972 43

Rooney, Hon. Fred B., a Representative in Congress from the State of

Pennsylvania, letter dated February 23, 1972, with enclosure 22

Additional material—

"Magazine Publishers Move to Improve Subscription Service, Expand

Open Subscription Dating on Magazine Mailing Labels," from the

Congressional Record of June 18, 1971 25

From the Buffalo, N.Y., Courier-Express, April 1971—

"Magazine Sales Tactics Under Fire" 3

"Housewives, Beware! Solicitor Must Sell" 4

"Customers Urged to Learn Safeguards" 5

"FTC Charges Deception by Publishers" 6

Reproduction of H.R. 8659, subject of this hearing 45

Administrative reports—

Office of Management and Budget 47

U.S. Postal Service 47
No
MAIL ADDRESS LABELS

THURSDAY, FEBRUARY 24, 1972

U.S. HOUSE OF REPRESENTATIVES,

COMMITTEE ON POST OFFICE AND CIVIL SERVICE,

SUBCOMMITTEE ON POSTAL FACILITIES AND MAIL,

Washington, D.0 .

The subcommittee met, pursuant to notice, at 10 a.m in room 219,

Cannon Building, Hon. Thaddeus J. Dulski (acting chairman of the

subcommittee) presiding.

Chairman DULSKI. The hearing will come to order.

This hearing concerns H.R. 8659, which I introduced last May.

I have a prepared statement and without objection we will have it

placed in the record at this point.

STATEMENT OF HON, THADDEUS J. DULSKI, A REPRESENTATIVE

IN CONGRESS FROM THE STATE OF NEW YORK

Mr. DULSKI. The purpose of the bill is very simple. It would amend

title 39 of the United States Code to require that mailers of periodical

publications print clearly on their address labels the expiration date

of the individual subscription.

The Magazine Publishers Association has been seeking for some time

to obtain the cooperation of its members in voluntarily adding a

clearly understood subscription date to the coded information which

most publishers include in their mailing label.

The association has compiled data showing that many publishers

resort to fancy codes for the expiration information so that it cannot

be deciphered by the average subscriber. A copy of the association

report has been submitted to the subcommittee for its reference.

My bill simply would require that the expiration date be included in

the code in such a fashion that the average individual would be able

to recognize easily the expiration date of the subscription.

This matter came to my attention in connection with the continuing

complaints which I have received and which are frequently reported

in the so-called action columns of many newspapers with regard to

irregularities in the sales of magazine subscriptions.

I am including at the end of my remarks a four-part series of articles which appeared in the Buffalo, N.Y., Courier-Express. This series

generated letters to me from area residents as well as from the newspaper itself.

Many of the complaints deal with door-to-door sales and extended

delays in the start of subscriptions following a partial or full advance

payment. These situations include allegations of fraudulent claims and

(1)
2

misrepresentations which are within the jurisdiction of the Federal

Trade Commission and other agencies for action.

Since the publications are delivered by mail, many individuals have

appealed to me and to our committee for action. In most cases the

criticism and the fraudulent actions deal with sales techniques which

occur on a personal basis and do not involve the mails. Thus, postal

regulations would not apply.

The one area where we in this committee can be helpful to subscribers is by putting into law what the Magazine Publishers Association is attempting to do through voluntary cooperation of the

publishers.

That is, in brief, to require that the subscription expiration date be

clearly identifiable on the mailing label of a periodical.

I can see no justification for periodicals to resort to fancy codes

which only they can read with respect to the expiration date.

Many of the complaints about magazine mailing would be eliminated if the subscriber could read the expiration date on the mailing

label.

The competition for magazine subscriptions is very intense and

every possible system is utilized in seeking to maintain subscription

lists, obtain new subscribers, and recover and reinstate lost subscribers.

Considerable of the solicitation activity is farmed out to agents and

organizations who are not responsible directly to the publishers. The

lines of communication are lengthy and subscription information frequently is outdated.

Some publications begin their campaigns for renewals many months

before the expiration date, and the renewal promotion material gives

no hint as to exactly when the subscription will expire.

I have had numerous individuals tell me that they have duplicated

renewals in advance of expiration because they kept no personal records and had no way of checking on the actual expiration date. They

discovered the duplications later, either by reviewing their checkbooks or otherwise learning that they had renewed for as long as 5 or

6 years in advance.

I am aware that the general counsel for the U.S. Postal Service

has submitted a report in opposition to the pending bill.

He argues that the information for mailing labels is a matter of

operational policy to be handled by administrative action. I know of

no such authority given the Postal Service or any action taken despite

the many complaints.

The Postal Service objects to the provision of the bill that would

require inclusion of the full name of the subscriber on the label.

The Postal Service argues that it has found that the lack of the

full name on labels has not hampered proper delivery of the mail and

that the abbreviations have held down the cost of computerized mailinp: lists for the publishers.

I feel that it is entirely proper to require more than simple initials

to be used with the last name of the subscriber because of the wide

similarity of names. It might help reduce the mixups in subscriptions.

I cannot believe that the fancy computers now in use would be unable to handle at least adequate abbreviations and stay within the

horizontal space on the label needed for the address.
0

I take sharpissue with the Postal Service's objection to the inclusion of the expiration date on the label for fear that it might complicate the mail handling. The new automated sorting equipment which

is being developed for the Postal Service must be able to read the

proper address lines and the ZIP codes.

There would be no conflict whatsoever with the publication's own

coded information line which already appears at the top of many, if

not most all, mailing labels.

I am not at all impressed by the statement of the Postal Service in

opposing requirement of an understandable expiration date on the

mailing label. The statement says:

Although this kind of information may be helpful to subscribers, it does not

aid the Postal Service in delivering the mail.

Even with its new independent status, the Postal Service still is an

arm of the U.S. Government, and therefore must be expected to consider the interests of our people while at the same time seeking to provide the most efficient and responsible mail service.

As I believe other testimony will indicate during this hearing, there

is considerable sentiment for the bill which I have sponsored. I hope

that the subcommittee will give its most careful consideration to the

pending measure.

Thank you for this opportunity to present my views.

The articles front the Buffalo, N.Y., Courier-Express will be made

a part of the record at this point.

(The articles referred to follow:)

[From The Buffalo, N.Y. Courier-Express, April 1971]

I—MAGAZINE SALES TACTICS UNDER FIRE

Inefficiency and misrepresentation are rife in the magazine subscription industry, a study by The Courier-Express indicates. This, the first of four articles

in a series, deals with some of the complaints registered against the industry.

(By Jim Watson)

A crescendo of complaints about unfilled subscriptions, billing foulups and unscrupulous salesmen is convincing testimony that something is very wrong in the

magazine marketing industry.

In many cases, the foulups may be the unintentional result of computer snafu.

But in some—notably in door-to-door sales—an intent to deceive is evident.

Thousands of Courier-Express readers have found themselves enmeshed in the

sticky web of corporate bureaucracy after paying for subscriptions to magazines.

Many of their complaints stem from lost or misdirected subscription applications, inadequate accounting services, and high pressure collection and sales

tactics.

Frustrated and angry, the victims turn to this newspaper's Courier Action collumn, a public service feature designed to help readers solve problems.

Here are typical comments from letters sent to Courier Action:

"One year ago I paid $7 for a magazine subscription (True Story) and have

yet to receive a single issue,"—R. A. Alden.

"I keep getting letters that I have not paid for my subscription (Dog Fancy)

but I sent the money by registered mail. I know they got It. . ."—E. R., Buffalo.

There are many more.

Even in this supersonic age, with space ships capable of circling the earth in 90

minutes, it still takes eight to 10 weeks for a magazine publisher to make a

normal adjustment on a subscription.

One Courier-Express reader waited even longer-21 months—for a subscription to be "adjusted." During that time, she never received a copy of the magazine, although the publisher had long since cashed her check.
4

The reader, from West Seneca, wrote the company three times asking why she

was not receiving the magazine.

Her first enquiry was ignored. The other two were answered with post cards

saying the matter was being "taken care of." She still received no magazines.

Courier Action solved the problem with a telephone call to the company's circulation manager. She received the first issue of her subscription within two days.

The circulation manager was "sorry" and said the woman's subscription "probably was lost in a mixup."

Few magazine publishers appear to feel concern about their dealings with the

"little people" who keep them in business.

One reader purchased a $10 subscription to Playboy magazine as a birthday

gift for his sister in April, 1970.

The company acknowledged the order and sent a gift notice to the recipient.

It was two months, however, before she received the first issue—and it was a

month old. Two more issues came in the mail the next month.

All three were sent back because the subscriber already purchased the issues

at newsstands. The subscriber explained the situation to the publisher and suggested: "Let's start over."

After ten months the subscriber still hasn't heard from the company and has

never received any more magazines.

A Niagara Falls woman purchased a $16 subscription to Modern Photography

and, instead of receiving the magazines, received three separate bills, each for

$16, after the company had cashed her check.

"We finally received three copies of the magazine but all were for the same

month, and two were dirty and torn," she said.

She wrote the company several times and received another issue of the magazine. She hasn't heard from the company since. Nor, has she received any more

magazines.

Other readers have received bills and "threatening" letters from magazine publishers demanding payment for things they never ordered.

Some threaten legal action and hint broadly a person's credit rating will

become worthless if payment isn't made.

Among other magazines about whose subscription practices Courier Action

has received complaints include Wrestling Revue, Popular Photography, Life,

Time, Ladies Home Journal, Football News, Look, Popular Science Book Club,

Popular Mechanics, Circus, Moneysworth, Midnight, Cat Fancy, Vintage Vehicles

and Car Classics.

Most of the circulation mixups appear to result from lack of coordination

between various departments of the publishing companies.

But the companies seldom suffer. The customer finds himself lost in unanswered

correspondence, wondering why the company cannot understand.

Many of the problems probably come up because much subscription soliciting

is not handled directly by magazine publishers. Agencies operating on franchise

often handle subscriptions.

The franchise owners employ solicitation crews, many of which work door-todoor, thus removing the subscriber even further from the publisher.

11—HOUSEWIVES, BEWARE! SOLICITOR MUST SELL

(By Jim Watson)

Spring is certain to bring the annual horde of door-to-door magazine salesmen

to the streets of Western New York.

Housewives can expect to be bombarded with myriad reasons why the solicitor

"just has to" sell a subscription.

Door-to-door sales crews are but one aspect of magazine marketing about which

The Courier-Express has received thousands of complaints from readers. The

complaints are convincing evidence that something is wrong with modern magazine selling methods.

According to the Better Business Bureau (BBB) of Western New York, the

types of false, misleading or objectionable personal sympathy appeals run a wide

gamut.

Those include salespersons representing themselves as "nursing students" . . .

"students at a local college" . . . "medical students" . . . "scholarship contestants" . . . "polio victims" . . . "foreign students."
5

Others claim they have families "behind the Iron Curtain" . . . need "funds

to enter a convent" . . . are "from an orphan home" . . . are "helping destitute

relatives" . . . are "refugees" from somewhere.

Mrs. Anne E. Norwood, local manager of consumer affairs for the BBB, recalls

complaints about a magazine salesman who claimed he was "studying to be a

brain surgeon." His manner, she said, indicated he never had received even a

high school education.

Complaints have come to the BBB from housewives who signed contracts for

unwanted subscriptions because they feared not to do so would indicate prejudice

against a minority group salesman.

One housewife complained she was threatened by a salesman and his two companions when she refused to sign a subscription contract.

The BBB classifies magazine sales personnel as "By Mail," "Paid During

Service" (PDS ) , and "Cash Crews."

"The 'by mail' complaints generally do not concern fraud or misrepresentation,"

Mrs. Norwood said. Complaints in that area usually involve slowness of delivery

or irregular billing.

The PDS crews engender a "fair amount" of complaints, she said, but most

complaints concern the 'Cash Crews.'

PDS crews usually represent local agencies operating on a franchise from a

subsidiary of a major magazine publisher. Their deals usually are packages

offered "for pennies" the balance to be paid in monthly installments.

"The subscriber is led to believe that, if he signs a five-year contract and

pays it up in three years, the magazines received during the last two years of the

contract are free," Mrs. Norwood said. "But . . . payments during the first

three years . . . are stepped up so the subscriber actually pays the full five-year

cost in three years."

PDS tactics sometimes start with a telephone call announcing, "you have won

a free subscription" or "you have been selected . . ."

The potential subscriber is told he will receive magazines for "only pennies

a week." Then an "agent" visits the subscriber's home with his "guarantee,"

actually a contract.

"Cash Crews" are "hit and run" salesmen who descend on a neighborhood,

working on volume.

The "Cash Crews" often are youths or minority group members or—particularly in the suburbs during the summer—pretty young women in short skirts.

"Cash Crew" members are generally prone to misrepresent themselves as

students or disadvantaged persons who are on the "brink of disaster" which

can be avoided only through a subscription sale to the resident.

Another "cash crew" tactic is misrepresentation as a "student" trying to

amass a certain number of points, usually 1,000, based on sales volume, to become eligible for a "prize" or "scholarship."

The solution to high pressure magazine sales tactics, according to Mrs. Norwood—and various local, state and federal regulatory agencies—is public

education.

In fairness, however, it must be said that not all magazine subscription solicitors are misleading or misrepresenting and the industry has taken some steps

to rid itself of the unscrupulous operators.

III—CUSTOMERS URGED TO LEARN SAFEGUARDS

(By James E. Watson)

Most authorities agree many problems encountered by magazine subscribers

could be avoided if the public knew its rights and the safeguards designed to

protect consumers.

"Generally, it's a matter of educating the public," according to Alfred B.

Silverman, assistant state attorney general in charge, Buffalo Office of the

Bureau of Consumer Frauds and Protection.

Silverman's office handles between 35 and 50 complaints annually about

"shady" magazine subscription salesmen. He delivers about 100 speeches a year

warning civic, religious and school groups about fraudulent selling.

He said he reaches about 25,000 persons annually with his talks, accompanied

by a film, "The Art of Fraud."

75-091 0-72 2
6

However, Silverman laments, "1 can give my speech and show the movie and,

sure enough, someone in the audience will sign a phony contract the very next

day."

Thousands of complaints about magazine subscriptions have reached The

Courier-Express.

Recognizing the problem, particularly in door-to-door sales, State Atty. Gen.

Louis J. Lefkowitz championed a consumer protection law which became effective in the state last Sept. 1.

The law provides a three-day "cooling off" period during which consumers

can cancel contracts for goods or services—including magazines—sold by doorto-door salesmen.

It applies only to contracts involving four or more installment payments or

cash contracts in which the seller provides the financing. If the buyer has spent

his own cash or money he borrowed independently, the law offers him no

protection.

Aimed at salesmen who use "surprise" and "hard sell" tactics to make the unwary sign questionable contracts, the legislation has requirements to be met by

buyer and salesman if the customer decides to cancel within 72 hours.

The customer's responsibilities include notifying the seller of the decision to

cancel. The seller must return any down payment and anything received as a

trade-in, and the customer must return any goods already received in substantially the same condition as when delivered.

However, the contract may not be canceled if the seller already has begun, in

good faith, what the law calls "a substantial performance." If the contract is

canceled, the seller may keep 5 percent of the total price—but not more than the

amount or any cash payment—as a cancellation fee.

Lekfowitz warns the elderly, busy housewives, the uneducated and those with

language difficulties in particular to look for notice of the right to cancel on any

contract peddled door-to-door. The notice—a card attached to the contract—includes a mailing form which can be used to notify the seller of a decision to

cancel.

Although the law says the customer must act within three days, Silverman

says his office is about 99 percent effective in getting door-to-door magazine contracts cancelled after longer periods. He studies all complaints received from

persons who feel a contract was misrepresented.

"If I feel the situation warrants it, I request the person or firm owning the

contract to cancel it," he said. "We invariably are successful."

Silverman has the power to subpoena and conduct hearings on contract matters but never has had to go to those lengths in solving magazine problems.

His office recently solved a problem for a Montreal, Que., woman who had

signed a subscription contract while living in Brooklyn. After she moved to

Montreal, the contract was sold by the original contractor to a different subscription franchise.

The contract's new owner agreed to terminate it at Silverman's request even

though the woman's only reason for wanting it cancelled was she no longer could

afford to pay for the magazines.

IV—FTC CHARGES DECEPTION BY PUBLISHERS

(By James E. Watson)

Most regulatory or enforcement agencies, such as local police departments and

the State Attorney General's Office, deal with suspected fraudulent magazine

sales at the "street level." But one government agency goes right to the top. That

is the Federal Trade Commission (FTC).

Last June, the FTC accused 14 major publishers and magazine agencies of

using "deceptive means" to lure long-term subscribers. Among those named were

publishers of "Look" and "Life," "Time" and "Sports Illustrated."

The FTC charged the magazines' salesmen mislead potential subscribers into

signing expensive contracts, then harassed them, if they fell behind in payments

or tried to cancel subscriptions.

The FTC complaints were against:

—The Hearst Corp. and its wholly owned subsidiary, Periodical Publishers'

Service Bureau Inc., Sandusky, Ohio; and International Magazine Service of

the Mid-Atlantic Inc., Baltimore, Md., a franchise of Periodical Publishers' Service Bureau.
7

—Cowles Communications Inc. and five wholly owned subsidiaries—Civic

Reading Club Inc., Educational Book Club Inc., Home Reader Service Inc., Mutual Readers League Inc. and Home Reference Library Inc., all of Des Moines,

Iowa.

—Time Inc., New York City, and its wholly owned subsidiary, Family Publications Service Inc., also of New York City.

—Perfect Film & Chemical Corp., New York City; its wholly owned subsidiary,

Perfect Subscription Co. of Philadelphia; and Perfect Subscription's wholly

owned subsidiary, Keystone Readers' Service Inc., Fort Worth, Tex.

Those cases are still pending.

In a separate action, the five Cowles subsidiaries were fined $10,000 Jan. 19,

after pleading no contest to criminal charges of using fraudulent and deceptive

practices in the sale of magazine subscriptions and book club memberships.

Potential subscribers were told they had been selected to receive 48- or 60-

month subscriptions to a wide range of popular magazines at no cost. However,

the court papers charged, the customers were told a "few pennies" would be involved each week for mailing and handling the "free" subscriptions.

The "few pennies," however, added up to full subscription costs—from $2.50

(to $6 a month) over 24 to 30 months.

Mrs. Ann E. Norwood, manager of consumer affars for the Better Business

Bureau of Western New York (BBB), calls the unqualified "only-a-few-penniesper-week" sales pitch "very misleading.

"Don't think you're going to get a bundle of magazines just by paying postage,"

she warns. A BBB pamphlet declares there is no such thing as a "free" magazine

subscription.

Although many magazine sales companies have good intentions, the industry

recognizes some unscrupulous salesmen and inefficient sales practices create

serious problems.

In self-defense, the industry set up the Central Registry of Magazine Subscription Solicitors (CR). A voluntary, self-regulating organization, CR is located

at 575 Lexington Ave., New York City, 10022. It is sponsored by the Magazine

Publishers' Assn.

Robert Goshorn, CR's head, said the agency investigates complaints and imposes fines against member organizations which violate CR codes.

CR's affiliated sales agencies post $1,000 or an equivalency bond, plus a $6,000

security bond with the magazine publishers. Goshorn said fines have been levied

against CR members, but he refused to reveal names.

The Buffalo Police Dept. Special Frauds Bureau receives relatively few complaints about door-to-door magazine salesmen. But suburban police sometimes

have their hands full.

Most police departments in the suburbs require managers and members of

magazine sales crews to register and purchase soliciting permits. Police warn the

permits may be canceled, if there are complaints of objectionable sales tactics.

Although lawmakers and public and industry agencies try to protect consumers

from fraudulent magazine subscription practices, the thousands of complaints

received by this newspaper show much more must be done.

Meanwhile, Western New York's frustrated and angry victims can continue to

turn for help to Courier Action, a public service column featured in The CourierExpress.

Chairman DuLsx.i. The first witness is Mr. Darwin E. Sharp of the

Mail Classification Division, U.S. Postal Service.

Mr. Sharp.

STATEMENT OF DARWIN E. SHARP, MANAGER, MAIL CLASSIFICATION DIVISION, U.S. POSTAL SERVICE

Mr. SHARP. Thank you, Mr. Chairman.

I am Darwin E. Sharp, manager, Mail Classification Division,

Finance Department, U.S. Postal Service. Accompanying me is Paul

J. Kemp, attorney, Legislative Division, Law Department.

I am here today in response to your request for the position of the

Postal Service on H.R. 8659, a bill which would add a new subsection
S

( c) to section 3685 of title 39, United States Code, to require that the

mail label or other cover of any publication having periodical publication mail privileges, when mailed to a subscriber, bear the following

readily intelligible information:

(1) The full name of the subscriber;

(2) The complete mailing address, including any code, or other

method maintained by the Postal Service to expedite transmission of

mail matter;

(3) The expiration date of the current subscription.

The bill also would renumber existing subsection (c) of section 3685

as subsection (d) and amend that subsection to authorize the Postal

Service to enforce the new subsection (c). After reading my prepared

statement, I will be glad to respond to any specific questions you may

have on the legislation.

Under the Postal Reorganization Act, the Postal Service has been

charged by Congress with the duty to "plan, develop, promote, and

provide adequate and efficient Postal Services at fair and reasonable

rates and fees." (39 U.S.C. 403 (a) .)

The determination of what information should be included on address labels, which the bill proposes to legislate, is a matter of operational policy to be appropriately, in our opinion, determined by Postal

Service management in discharge of its general duty to provide adequate and efficient postal services.

We believe that amendments to the Postal Reorganization Act to

legislate matters affecting day-to-day postal operations are unnecessary

and could prove harmful.

Postal regulations currently require the proper addressing of mailed

periodical publications. The inclusion of the name and address of

the addressee is specified in 39 CFR section 122.7. The inclusion of

necessary ZIP codes is specified in 39 CFR section 25.3(B) (5) .

As to the bill's requirement that the full name of the subscriber be

placed on the label, our current regulations do not forbid the common

practice of abbreviating first names, since we have not found the full

name to be necessary for proper delivery of the mail. Moreover, we

understand the reason for such abbreviations is basically one of the

added cost to publishers of carrying the full name in their computeraccessible records.

Accordingly, it is our opinion that including the full name may be

an unnecessary economic burden, and we would therefore not be inclined to require it at this time unless significant countervailing benefits accrued to subscribers.

However, the Postal Service has the authority to require this information if it becomes desirable to do so, and consequently legislation is

not necessary to provide for it.

-While Postal Service regulations do not require inclusion of the

expiration date on the mailing label, they do permit, as additions to the

envelopes or wrappers of periodical publications, "Written or printed

words or figures, or both, indicating the date on which the subscription

will end." (39 CFR section 132.4(G) (2) (V) .)

We know that many publishers voluntarily include this information

in some form on the label. Although this kind of information may be

helpful to subscribers, it does not aid the Postal Service in delivering

the mail. Indeed, the addition of words and numbers, in too close
9

proximity to the address might interfere with the use of address reading machinery which the Postal Service hopes to develop and use in

the fut tire.

If mail delivery should be impeded for this reason, some amendment of the above regulation would be in order. Therefore, we believe

it is unnecessary and could prove harmful to require by statute information of this nature.

As I have outlined, the Postal Service believes enactment of H.R.

8659 is unnecessary and could prevent the achievement of improved

mail service, by freezing in statutory form requirements which should

be imposed, if at all, through the more flexible regulatory approach

presently available to the Postal Service. Accordingly, we oppose the

proposed legislation.

This concludes my prepared statement.

Thank you very much, Mr. Chairman.

Chairman DIILSKI. Thank you, Mr. Sharp.

I am not going to take any issue with the statement that you have

here. This is the statement prepared by the Postal Service. I made

my position clear in my own statement at the beginning of the hearing.

How much would it cost the Postal Service to give better service?

Will this proposal cost the post office any money? Is that why you

oppose it?

Mr. SHARP. There could be some cost if we administratively enforced the letter of the statute. For instance, if the full name of the

subscriber were to be a condition to maintain periodical privileges, we

would have to examine individual copies to assure that the full name

was in fact there.

We would also be forced to contact publishers, and perhaps customers of the publisher, their subscribers, in the event that some subscribers would indicate that the publisher could use their initials

instead of their first names.

I personally, for example, often order my subscription as D. E.

Sharp, and that's my name as far as a publisher is concerned. If the

Postal Service had to provide the full name as information for the

publisher, that would involve extensive administrative cost. I cannot

predict precisely what would be the cost for that.

Chairman DITLSKI. Let's get down to cases. I am suve that you have

many good points. How would you like to get a notice? Do you keep

track of the subscriptions that you apply for?

Mr. SHARP. Yes, I do.

Chairma nDu-Lsiii. You put on your check, "My subscription expires" so and so?

Mr. SHARP. No. I date the check and I put "for x number of years."

Chairman DuLsx.i. I am asking you, do you remember when you

filed for a 2-year, 3-year, or 1-year subscription? Where do you have

that record? Do you keep that record for yourself so that you know

that it's going to expire on such a date?

Mr. SHARP. I keep my checks.

Chairman DuLsiii. I know you keep the checks. That has to be

returned to you. Do you remember your expiration date when all of

a sudden there is a notice in the mail that says, "We will give you

a special deal at $3"—one of those $3 or $2 deals, whatever the figure

is—"if you extend your subscription to our magazine at this time?"
10

When you get that notice you send the check in and, I don't know,

maybe they extend it and maybe you do get a better deal. But, do

you remember when your subscription expires?

Mr. SHARP. No; I would imagine 

Chairman DuLsxt. That's what I thought. None of us do. I don't.

This is one of the reasons for the bill. Sometimes it's a valid renewal.

But sometimes a subscriber discovers he has a 10-year or 5-year subscription. This is because I, for one, don't keep track of when my subscription expires.

What amendments would you suggest to the bill in order to meet

your objections?

Mr. SHARP. I have no specific suggestions, I believe, right now.

The Postal Service has the authority to require all of the address

information which is necessary for us to deliver the mail, and this is

our primary interest.

Under existing legislation, we have this authority. I also believe—

and I would like to defer to counsel on this—that there is existing

authority under the FTC regulations to prescribe certain protections

for the subscriber without legislation.

Chairman Dutisxt. Would you identify yourself for the record?

Mr. KEMP. I am Paul J. Kemp, attorney, Legislative Division,

Law Department. We think there may be some doubt as to our authority to require the expiration date. It's not altogether free from

doubt. We look upon this provision as a consumer protection measure

rather than one of mail delivery. An expiration date doesn't really

help us, as Mr. Sharp testified, to deliver the mail, but we do have

some consumer protection functions.

However, the Federal Trade Commission—I am not speaking for

them—could possibly issue a trade regulation rule if the facts warranted it, if it were sure that people were being defrauded because

the expiration date was not on the publication and they held an administrative proceeding for that purpose.

We feel that they have authority to issue such a rule and require

the expiration date to be put on publications. It's possible we could

work in cooperation with the FTC on this matter.

Mr. SHARP. Mr. Chairman, may I make a further comment?

Chairman DuLsiii. Go ahead.

Mr. SHARP. In terms of the specific language of the legislation, it refers to a subscription expiration date for all periodical publications

having those privileges. There are certain periodical publications

which are excluded from the requirement to have a legitimate list of

subscribers; they do not have subscription termination. Some publishers may be entitled to a periodical mailing privilege where control of circulation is desired and the publication may be designed primarily for free circulation. As such, the subscription expiration date

for these publications would be best determined by the publisher

rather than under contract between publisher and subscriber.

Now to monitor individual publications and go back and make administrative checks on whether or not the mandatory subscription expiration date was really what the publisher claimed it to be—for

example, this would impose an administrative burden on the Postal

Service.
11

Chairman DIILSKI. Mr. Sharp, in your statement on page 2, you

say

Under the Postal Reorganization Act, the Postal Service has been charged

by Congress with the duty to "plan, develop, promote, and provide adequate and

efficient postal services at fair and reasonable rates and fees."

This is not the subject of this meeting, but at the end of that reference you say, "And could prove harmful." We may want an explanation of that statement as we turn this matter over in our minds. I

will tell you, I wish you could see all the complaints flowing in about

postal service. I have never had so many complaints about postal

service, about the deterioration of postal service.

Recently there was a critical editorial in the New York Times followed a few days later by a big spread of concurring letters to the

editor. And you say this bill is going to prove harmful.

I say that anything we do would be an improvement, I can assure

you of that. Can you explain what you mean when you say "It could

prove harmful?'

Mr. SHARP. Yes, sir. In mail classification, if I may use an example,

we have recognized that under the requirements of the new legislation

the rates for second-class publishers must be increased.

What we are working on are certain plans to mitigate the administrative costs of doing business with the Postal Service on the part of

the publishers.

We have very recently, for example, had a meeting with representatives of large publishers and publishing organizations to introduce the

possibility of preparing mailing statements on computers and doing

away with multiple deposit points. We are making efforts toward

easing the administrative burden to mitigate the effects of great increases which are necessary under the new law.

Now, if any legislation which would impose 

Chairman DuLsiii. I am not talking about that. Why don't you

answer my question? I am talking of this bill, H.R. 8659. Just tell me

where it's going to be harmful. That's all I want, Mr. Sharp.

Mr. SHARP. We will incur additional administrative costs in monitoring the full names and monitoring expiration dates and in answering

complaints about any expiration date printed on the label which is,

in fact, proven to be erroneous. This would cause us to incur additional

cost. Our additional administrative costs in monitoring what are basically second-class publications would increase the attributable cost of

second-class publications, a cost which must be passed to the customer

who is doing business with us. Since this information is not required

for efficient delivery of the mail, yet is an administrative burden which

must be passed on to the publishers, the bill could prove harmful to our

efforts toward providing good service at the lowest feasible rates.

Chairman DuLsiii. You made a statement a few minutes ago about

protecting the consumer; is that right? Did you make that statement?

Mr. SHARP. Mr. Kemp did.

Chairman DuLsici. Do you think it would be protecting the consumer if he knew when the expiration date was on the subscription?

Mr. SHARP. Yes, sir, I believe that putting the expiration date of

the subscription on the label might, in fact, benefit the consumer; but

I view the contract between a subscriber and a publisher as basically
12

that, and believe that the Postal Service, in. Federal legislation which

it should enforce or rules and regulations which it promulgates,

should require only such rules as are necessary for the efficient delivery

of the mail.

And as Mr. Kemp said, if it is required for consumer protection,

then perhaps another agency should monitor it and we should not

have the administrative burden of monitoring it.

Chairman DuLsKi. Let me give you an example. It is none of your

business when I bought a subscription. It's none of your business, none

of the post office's business when it's going to expire, but I am going

to have the expiration date on the label. There is no stopping the delivery of the mail if the magazine label says in some clear manner:

"Your subscription expires September 30, 1972."

Yet you are using the word "harmful." Just by including the expiration date—that won't cost you a penny. You say you are interested in

the consumer. There are two sides of the fence.

Mr. SHARP. Right. The amendment- which would be provided for in

subsection (d) would authorize the Postal Service to enforce this new

subsection (c) , so there is an enforcement provision in the proposed

legislation which would make it incumbent upon the Postal Service to

monitor it. The Postal Service is interested in 

Chairman Duristu. Counsel tells me they would rely on the complaints from the consumers.

Mr. SHARP. If we relied on the complaints of the consumers, if we

were charged with the enforcement of this, we would still have to

establish an administrative apparatus to handle increased correspondence from the consumer and, also, to do the investigative work that

would be necessary at the publisher's plant to determine whether or

not the consumer's complaint was, in fact, valid.

The expiration date of publications, of course, is of some interest to

the Postal Service in its annual verification. One of the conditions for

maintaining second-class mailing privileges is that the primary intent

for circulation be to legitimate paid subscriptions. We must assure

that publisher records indicate paid subscription expiration dates. So

annually, in many situations every 5 years we have to verify records to

determine paid subscribers, and examine receipts and cash books to

validate the fact that publications are circulated to legitimate paid subscribers. There is that interest on our part.

Chairman DULSKI. I have no further questions.

Thank you very much, Mr. Sharp and Mr. Kemp.

Our next witness is Raymond Williams, area consultant for the Virginia State Library, on behalf of the American Library Association.

We are very happy to see you, Mr. Williams.

STATEMENT OF RAYMOND E. WILLIAMS, AREA CONSULTANT FOR

THE VIRGINIA STATE LIBRARY, ON BEHALF OF THE AMERICAN

LIBRARY ASSOCIATION

Mr. WILLIAMS. I am Raymond E. Williams. I am the area consultant

for the Virginia State Library and I am a member of the American

Library Association.
1$

I would like to read my statement, if I may.

Chairman DULSKI. Go right ahead.

Mr. WILLIAMS. The American Library Association heartily endorses

H.R. 8659, the bill to amend title 39, United States Code, as enacted

by the Postal Reorganilation Act to require that the mail label or other

cover of any publication having periodical publication mail privileges,

when mailed to a subscriber, shall bear readily intelligible information

regarding the name and address of the subscriber and the expiration

date of the current subscription, and for other purposes.

The association, a nonprofit education organization, made up of 14

divisions and comprising over 30,000 librarians and other publicspirited citizens dedicated to the development of libraries of all kinds

for the advancement of the scientific, educational, and cultural progress of the American people, urges prompt and favorable action by

the committee on this highly significant legislation.

This position is based not only on extensive personal investigation

but on the experience of countless librarians throughout the country.

I have been a librarian for 32 years and have served in New York

State at Rochester, Elmira, and Watertown; in Connecticut at Hartford; in Baltimore, Md., where I was assistant director of the Enoch

Pratt Free Library for over 6 years; in Minneapolis where I was the

chief librarian for 7 years; and in Charlottesville, Va., where I was

the director for over 7 years; and am now an area consultant for the

Virginia State Library.

In all of these libraries and for all of these years, one of the most

confusing and irrating parts of library administration has been the

servicing of the periodical collection.

Periodicals are essential for the provision of good reference service,

but the records are liable to be in a constant state of chaos. Subscriptions may not be completed, individual numbers may not arrive, or if

they do, they may appear late, the format of the periodical may change

in size or shape in midvolume, and most important, for the purposes

of this bill, the customer has little or no information on the true date

of the expiration of his subscription in an overwhelming number of

cases.

In preparing this testimony, I used the periodical collection of the

McIntire Public Library, Charlottesville, Va., as a source of information. This is a typical medium-sized library among the 7,000 public

libraries in the United States. It serves 80,000 people, has a book collection of 115,000 books, a staff of 26, a budget of $270,000, and an

annual circulation of 365,000 books per year.

It also subscribes to 240 periodicals (almost all of which are indexed in national indexes) and receives a number of gift subscriptions which may or may not be indexed.

The subscription title selection is quite orthodox among the most

used national magazines. Of the 100 leading U.S. magazines (determined by circulation by the Magazine Advertising Bureau of Magazine Publishers Association, Inc., as reported in the World Almanac

1971) , the McIntire Library subscribed to 46 and received five by

gift.

The 46 subscription periodicals are included in the sample of 197

examined and analyzed below and the list of the other 49 plus the

five gift periodicals follows.

75-091 0-72 3
14

8

42

4.1%

Plain language - correct date

21.3%

Plain language - wrong date

- no year

11 5.6%

Coded - correct date

22 11.2%

Coded - wrong date

47 23.8%

Coded - Unidentifiable

67

No date

34.0%

197 100.0%.
15

Periodicals in the list of 100 highest circulation which are not subscribed to by the

McIntire Public Library, Charlottesville, Virginia.

TV Guide Ingenue

Woman's Day TV Radio Mirror

Family Circle Modern Screen

Playboy Teen

Redbook Presbyterian Life

American Legion Modern Romances

True Simplicity Fashion Magazine

True Story Lion Magazine

Elks Magazine - gift Flower and Garden Magazine

VFW Magazine Motor Trend

Jr. Scholastic Lutheran - gift

Glamour Catholic Digest

Workbasket Ladies Circle

Argosy Car and Driver

National Inquirer McCall's Pattern Fashion

Sports Afield movie Mirror

Today's Education Family vandyman

Scouting Our Sunday Visitor

Grit Motion Picture

Progressive Farmer - gift T.airdo & Beauty

Sport Together

Successful Farming Canner's Weekly

News Time West Ways

Cosmopolitan True Confessions

Columbia - gift Vogue Pattern Book

1001 Decorating Ideas National Future Farmer

Co-ed Rotarian - gift
16

Mr. WILLIAMS. The mailing label was removed from a recent copy

of each of the periodicals and attached to a card which shows the name

of the periodical, date of the issue used and the library's record according to invoice of the date of expiration of the subscription.

The cards were then sorted into six groups and marked as shown

on the chart with the number in each category and the percentage

frequency of the class or group.

Now at this time I would like to hand these over to the chairman,

the cards I was talking about. These are the basic documents.

(Mr. Williams hands documents to the chairman.)

Mr. WILLIAMS. And then I have some Xerox copies of the cards.

Counsel may wish to have one set and other members of the committee—maybe Mr. Nix.

As can be seen by an inspection of the cards, out of 197 periodicals

there were only eight that had the correct date in plain language that

was the same as the date on the invoice to the library—only eight out

of 197.

Next, 42 had plain language dates but they were incorrect as far

as the invoice was concerned. It wasn't the same date.

There were 11 out of 197 that were coded but could be recognized

easily that had the correct date, and there were 22 that were coded

and recognizable but with the wrong date; it wasn't the date of the

invoice. The date on the label was different from the invoice date.

There were 47 out of 197 that were coded and they were completely

unidentifiable. I have a pretty good imagination, but I could not

decipher 47 where the message across the top was coded.

There were 67 out of these that had no date, just the address.

As can be seen by an inspection of the cards, even when the coded

date is correct, it is necessary in most cases to know what date is being

sought in the code to be able to recognize it as correct.

Conclusions: (1) With 19 of 197 or less than 10 percent of the

expiration dates correct, there is either a complete lack of information

at some point in the periodical supply business or there is purposeful

beclouding of the information, and the customer is one of the ones

to whom the in formation is denied.

(2) If a standard notation on the mailing label were required, the

thousands of unnecessarily lost man-hours and expensive correspondence would be saved, and believe you me, the library does spend that

time, plus giving a sense of trust in the record.

(3) I am sure that libraries would prefer to pay for what they get,

and get what they pay for, and add the cost of handling and servicing

periodical subscription lists to the invoice. They would then, of

course, not have to wonder about what happens to the money represented by the difference in expiration date noted on the label and the

expiration date shown on their invoices.

(4) I am also sure that individuals would welcome an exact notation of the time limits on a subscription purchased.

Here is a suggestion for a notation which is code readable and

machine readable and this would indicate the last issue to be sent to

the customer unless a subscription is renewed in writing: For dailies,

weeklies, et cetera, EXP or XP 2 22 72. For monthlies, EXP or

XP 2 72.
17

The problem is so critical because periodicals are an invaluable

reference resource, particularly for current information. From the

examples I have used you can see the seriousness of the situation for

Charlottesville. Imagine the magnitude of the problem for the Philadelphia Public Library which annually adds 2,250 serials to its collection, or the University of North Carolina system which receives more

than 15,000 periodical titles in a year.

I should explain that. The 15,000 titles are added throughout the

North Carolina University system. Actually, there are 5,497 at the

Raleigh campus, 5,649 are carried in Chapel Hill; 1,717 at Charlotte;

2,347, adding up to over 15,000. But this of course represents a duplication of titles in many cases; however, the scope of the problem is

indicated by the fact that 15,000 periodicals must be dealt with.

We are grateful indeed for the committee's consideration of the

matter and urge early and favorable action on H.R. 8659.

Chairman DuLsKi. Thank you very much.

Mr. WILLIAMS. Now, sir, that's the end of my prepared statement.

I would like to let you know what I have here and then see whether

there are questions you want to ask.

It was in July when I collected the facts for this testimony after

your bill had been introduced. I had been thinking about this a long

time personally, but then, I began a minute search, and I talked to

the Legislation Committee, the Trustees Association, and the Public

Library Association of the American Library Association, at our

annual meeting in July. When the call came on the 10th of February

that there would be a hearing, I realized that there might be some

doubt or some comment as to whether my facts were up to date.

Everything has changed since July, so I went through a new pack

of cards and put on new labels from the same group of periodicals. I

didn't add any. I just used the 197 and the results of that search are

here, and again

'

I would like to show you the results. I went through

this to see what changes had occurred. The Baltimore Sun, for instance, has changed from plain language to a coded one, but it is the

wrong date.

House and Garden went from plain language to wrong date plain

language. The changes and the differences can be summarized as

follows:

Of the original sample of 197, two have ceased publication. Of the

197, eight are no longer received for one reason or 'another, either

cancelled or they are just not coming and that makes 187 in the new

sample. No labels had been received by Tuesday, February 22, on 43

of the periodicals. Of the remaining 144, 21 had changed label information and 11 had given more information, 8.9 percent; 7.3 percent had

changed to less information, and one went from no date to unintelligible, which to me, is nothing to nothing.

So you end up with just about an even-steven-even-trade. They may

have changed since July but nothing has changed to improve it. This

is kind of messy for anybody to deal with but I do have Xerox copies

of this compilation with the new labels and I will leave three of those

here.

Chairman DuLsm. We will put them in our files.

Mr. WILLIAMS. Now I think that completes my testimony. Any

questions you would like to ask?
18

Chairman DIILSKI. First, Mr. Williams, I want to commend you for

the job you have done. You have actually made a thorough study of

this basic problem.

Mr. WILLIAMS. Well, it's been irritating for 30 years, as I said, this

goes on and on and on and I wanted to prove to myself—my file here

is entitled "Expiration Date Crusade" and that is an old file. I have

been thinking about this for a long time. I have been irritated all of

this time.

Chairman DtTLSKI. You know the reason I am hesitating about asking you questions: You are quite an expert on this subject and I would

like your testimony to stand on its merits.

What would you say concerning this pending legislation, do you

think this would be harmful to the Postal Service?

Mr. WILLIAMS. Do you want me to answer very frankly?

Chairman DITLSKI. Answer any way you want to.

Mr. WILLIAMS. I think I can understand why the Postal Service

is submitting the testimony they do, and they are trying to defend the

parameters of their authority to the Postal Service. I can understand

that.

But, I don't understand why it would be harmful, if anything like

this were included in the top line, not necessarily in the line with the

name where it might interfere but in the top line. Maybe the full

name is not necessary, but the address should be on it.

So all of that computer line at the top ought to be eliminated from

all labels if that is harmful for the mailing. If it isn't in the way of

getting mail out to people, then certainly among the things up there,

you can put on a date which is code readable or is printed, mimeographed, or dittoed, or whatever.

I just can't see any possibility of this being in the way of the

Postal Service. Now, maybe they feel that they shouldn't have legislation to do this, but they jolly well better take into account the customerconsumer relation aspect, that we need to know when our expiration

dates come.

The evidence is here. People are being taken. This is just the library.

Think of all the individuals. Think of me with my home subscriptions; I am being taken through the cleaners. A check doesn't do any

good. The only receipt that you really have of what you are getting

for periodicals is on the mailing label. Now, they could do it some

other way. For instance, there is the statement from the Magazine

Publishers Association. I have the statement here. They have given

the expiration dates and how you find them in the code and that is a

mighty interesting document. It shows how they bury things—take

the first one, American Heritage, just to pick an example, the 19th,

20th, and 21st digits in the code line show the date. The months are

coded A through L. Now, that's good.

All right, in this line it says B70302AAMSJ90206H4J690L181H

and we are using their approach to a lettered month. This is not the

letter of the month and a year date. I would pick out one, two, three,

four, five places where a code such as they have could indicate an expiration date in that line and within reason, within a normal expiration

date period.

It could be B70, or J9; it could be H4; it could be L1, all of these

things would fall within this code except they wouldn't be the 19th,
19

20th, and 21st digits. This goes on, I mean, this is the way so many of

them are done, and frankly, it's just a way of deceiving the customer

in my opinion.

Chairman DULSKI. Mr. Williams, I have a question, Has it been the

library association's experience or the association's that the publishers

refund overpayments on subscriptions resulting from early billing or

do they merely extend the subscription?

Mr. WILLIAMS. I think that varies a good deal. Sometimes a periodical goes out of existence or is combined with something else.

Chairman DULSKI. No, let's use an example of a subscription that expires in July. They mail me a renewal form for such and such a magazine at $3. I just take it for granted that the subscription has alreay expired, so I mail them another $3.

I am not reflecting on anyone, I have a great deal of faith in the

publishers, I am sure they don't keep the money. They extend me for

another year.

Mr. WILLIAMS. Mr. Dulski, I think this is more the way individuals

operate on subscriptions; that isn't the way libraries operate.

Chairman DULSKI. I am talking about individuals who are being

taken.

Mr. WILLIAMS. You and I with our subscriptions, we have this problem, and we have the same thing happen. You went through it before,

yes, it may be added to, but I don't know what the expiration date

really is. I don't have a contract that says from them definitely it expires on such and such a date.

Now, for libraries, we normally have a list of magazines which is

subscribed to by the year and they have a comon expiration date if

we can get the jobber to arrange for a common expiration date. And

each year you have your list of periodicals and you have the bill for the

periodicals that are subscribed to that year.

It seems reasonably right, and I mean it is within the reasonable

amount that it would cost, and you pay your bill. It is usually anywhere from August to November that you would pay your magazine

subscription bill for the bulk of your periodicals, and then the magazines come on.

Well, if something happens and you aren't getting your subscription, when you get back to the jobber, you say, "Come on, where are

they?" If they keep on, and you get your periodical over the next

year, then the following year you have your bill and you generally go

over the bill and you see that, yes, certain of the subscriptions have

been clubbed together and you get a 33R2 rate. They tried to do that,

and this is good.

But when you get right down to the nitty-gritty and you try to find

out just what date is on your invoice and what date is maybe on the

label, you find there is a good deal of difference. Some are early, some

are late.

Who picks up the difference? Well, I don't know. I am not going to

be beyond that. That fact is it's different than you think it is.

Chairman DULSKI. I believe that you already have testified that

some publishers already are printing the expiration date on the label?

Mr. WILLIAMS. Yes, they are.

Chairman DULSKI. I will tell you I am very much impressed with

your testimony and I am sure that the chairman of the subcommittee,

Mr. Nix, regrets very much not being here to hear your presentation.
20

'Unfortunately, he had a very important meeting in his own district

in Philadelphia which he was obligated to attend.

I appreciate your comments and information. I am sure if we should

need any additional information you will be available and we can

contact you.

Mr. WILLIAMS. Anytime you feel you need any information, if there

is any way, I will be happy to assist you. Now, Miss Krettek as you.

know is with the Washington office of the American Library Association, and she is in touch with the counsel here. Anytime that the association can be of help, she can contact me or other members who

would be glad to be of service.

Thank you very much.

Chairman DULSKI. Could we have a copy of that letter of the Magazine Publishers for the record? Never mind, sir, I am told we have a

copy.

Mr. WILLIAMS. Just for fun and I guess it's more like the devil's

advocate, if the Magazine Publishers Association had each publisher

send out this little manual with each subscription so that everybody

could decode his own subscription, that would do it.

Chairman DuLsKt. Thanks again.

Before closing the meeting, we have a submission by our distinguished colleague, Mr. Fred B. Rooney, who is supporting this legislation. He has submitted a letter and an article from the Congressional

Record.

We also have a letter from the American Farm Bureau Federation.

Without objection, they will be included in the record at this point

and the committee stands adjourned subject to the call of the

Chair.

(Whereupon, at 10 :45 a.m., the subcommittee hearing was adjourned.)

(The letters referred to above, plus additional materials, follow:)
21

American Farm Bureau Federation

February 23, 1972

Honorable Robert N. C. Nix, Chairman

Subcommittee on Postal Facilities and Mail

Committee on Post Office and Civil Service

U. S. House of Representatives

Washington, D. C. 20515

Dear Mr. Chairman:

WASHINGTON OFFICE

42 5 13,-, STREET. N W•

WASHINGTON. D.0 20004

AREA CODE 202 - 838 • 5315

CABLEADDRESS:ANIFARNIBUR

The American Farm Bureau Federation, a general farm organization representing the

2,057,665 member families of 49 State Farm Bureaus and the Puerto Rico Farm Bureau, is

seriously concerned about the possible consequences of the enactment of H. R. 8659.

The American Farm Bureau Federation, the member State Farm Bureaus, and many of the

more than 2,800 County Farm Bureaus publish several hundred magazines, newspapers, and

newsletters which are entered as second class matter with the Postal Service.

Nearly all of these publications are paid for by Farm Bureau members as a part of their

voluntary payment of dues. The subscription year and the membership year are identical.

Membership cards clearly state the length of the membership year or period, which

varies from state to state. For this reason, we believe repetition of this information on the mailing label for each issue of each publication would serve no useful

purpose.

Because farmers move infrequently and because the majority of Farm Bureau member families

retain their membership for long periods, it is not necessary to prepare new mailing

information for the computer on an annual basis for the majority of subscribers to

Farm Bureau publications.

Passage of H. R. 8659 would require new labels to be prepared each year and would result in much greater costs to publishers of Farm Bureau publications.

We have not protested the sizable increases in second class postal rates and the various

rulings, such as those pertaining to zip codes, which have had as their objective more

efficient handling of the mails. It is a fact, however, that these have added, greatly

to our costs.

It appears to us that passage of H. R. 8659 would add further to our publication

costs without benefiting either our members or the Postal Service.

We respectfully recommend that H. R. 8659 be amended to exempt publications paid for

wholly or in part through dues paid to nonprofit organizations.

We appreciate this opportunity to present our views on this important matter and we request that this letter be made a part of the hearings on H. R. 8659.

Sincerely yours,

Marvin L. McLain

Legislative Director

75-091 0 - 72 - 4
22

CongrecZ of tbe tiniteb iptafeci

31)ouSe of RepreOentatibeO

atibingtort, 39.C. 20515

February 23, 1972

Honorable Robert N. C. Nix

Chairman

Subcommittee on Postal Facilities

and Mailing

Roam 13345-B

Washington, D.C. 20515

Dear Colleague:

A long-standing commitment to meet with officials from my Congressional District and representatives of several federal agencies

today precludes my personal appearance in support of H.R. 8659 introduced by Mt. Dulski.

With your permission, however, I would like to offer the following

comments for inclusion in the Record of these proceedings. These comments are based upon information gleaned from a three-year investigation

I have conducted into the sale of magazine subscriptions.

Briefly, I discovered, for example, that it was a common practice

within the "pay during service" (budget payment plan) segment of the

subscription sales industry to offer for sale multiple, long-term

magazine subscriptions on a single contract and then to alter the terms

of certain of those subscriptions without the consumer's knowledge or

consent.

Subscription contracts which supposedly specified four years of

subscription service or five years of subscription service for each of

three, four, five or more individual magazines, were freguently--and in

cases regularly—altered by the sales personnel to provide shorter

periods of subscription service than the contract had indicated. This

practice is commonly known in the industry as "shaving" a contract and

my files contain thousands of examples. During testimony in a civil

proceeding in Pennsylvania, for example, an employee of a sales agency

described how he regularly shaved most of the contracts he handled.

The following description of shaving is extracted fram a summary of

magazine subscription selling abuses which I compiled during the course

of my investigation:

"Shaving" contracts--A process of "shaving" months or years off

the length of subscriptions to reduce the total value of subscriptions shown on a PDS contract. Shaving is utilized in several

ways, such as:
23

"A. A salesman, to reduce a consumer's resistance, offers a larger

number of four-year or five-year subscriptions than the total

contract cost will cover. (A rerber of my staff was offered

five-year subscriptions to seven magazines having a total

value $30 higher than the total contract cost.) Then, after

the sale and without the subscriber's knowledge, the salesman

"shaves" nonths or years off some of the subscriptions to

reduce their caMbined value to equal or nearly equal the contract's total cost. The subscriber generally does not discover

until years later, when his subscriptions run out prematurely,

that he has been deceived.

B. A salesman, to collect special cash bonuses offered for selling

subscriptions to certain magazines attempting to increase

circulation, may shave years or months off subscriptions appearing

on the contract, thereby reducing the value of those magazines

far below the contract's total cost. This produces a dollar

surplus ("water") in the contract which the salesman utilizes

to add one or more unordered subscriptions which pay him cash

bonuses. These add-ons are accomplished without the subscriber's

knowledge and result in the subscriber receiving magazines

he never ordered. But since service of the ordered magazines

also begins, the subscriber may assume the others to be gifts.

Not until the subscriptions for the ordered magazines expire

prematurely is he likely to suspect he's been deceived. Because

the average consumer neglects to record when subscriptions

are due to expire„he may never discover the deception.

(Recently, examination of records of a single franchise produced

several thousand contracts which had been manipulated in this

manner. Unordered subscriptions estimated to total as much as

20,000 years had been secretly entered on the contracts.)"

For the past two years, I have made repeated appeals to the Magazine

Publishers Association to voluntarily adopt open dating of magazine

subscription expiration dates on railing labels. Tast spring, MPA initiated

a voluntary open dating program which I cited in the Congressional Record

on June 18, 1971. I also inserted in the record at that time a key to

decipher the coded subscription expiration dates of several hundred magazines. But only a fraction of NM member publications have voluntarily

adopted open dating.

The need for open subscription dating on nailing labels is evident

in the hundreds of requests I subsequently received fram libraries

across the country for copies of the key to read subscription dates. It

is evident, too, in many letters of complaint which I received from libraries and consumers alike, expressing frustrations that they could not

determine whether they were receiving full value subscription service.
24

If open subscription expiration dates are printed on mailing labels,

the subscriber can determine instantly whether any new subscription was

entered for the proper period of time. He thus can take immediate steps

to correct any error. But if he cannot read the expiration date which

virtually all magazine mailing labels already carry in some form--either

legible or coded--he is virtually helpless to determine whether he is

getting what he paid for. And although one might suggest the subscriber

always can write to the publisher and inquire about the date, my own

experience indicates that many consumers' letters are never acknowledged

until some official inquiry is made on the consumer's behalf, and sometimes not even then.

Should you desire additional information, I will be pleased to

respond to questions you may have or to supplement this letter with material

which may be available in my files.

With kind personal regards, I am

Sincerely yours,

(7611419.—

ed B. Rooney, M.C.
25

MAGAZINE PUBLISHERS MOVE TO

IMPROVE SUBSCRIPTION SERVICE, EXPAND OPEN SUBSCRIPTION

DATING ON MAGAZINE MAILING

LABELS

The SPEAKER pro tempore. Under a

previous order of the House, the gentleman from Pennsylvania (Mr. ROONEY)

is recognized for 30 minutes.

Mr. ROONEY of Pennsylvania. Mr.

Speaker, I am pleased to call the attention of my colleagues to a breakthrough

in timely and accurate servicing of magazine subscriptions.

In conjunction with a two-and-a-halfyear investigation of magazine subscription sales methods which I have been conducting, I urged the Magazine Publishers

A.,sociation in October of 1969 to initiate

"open dating" of subscription expiration

dates on magazine mailing labels.

At that time—October of 1969—although virtually all periodicals included

subscription expiration dates in the

jumble of numbers and letters which

commonly appear above the subscriber's

name and address on a magazine mailing

label,' the great majority of periodicals

printed the date in some code which the

average subscriber could not decode.

Thus, librarians and individual subscribers often were at a loss to know if

subscriptions they purchased actually

were entered for the proper period of

time. And because of widespread selling

abuses by subscription sales agency personnel my investigation of magazine selling practices had documented, it was

readily apparent that numerous subscribers were being shortchanged on

magazine service—that is, they were receiving fewer 'issues of magazines than

they had paid for. Frequently, when a

long-term subscription expired prematurely several years after it was purchased by a consumer, the consumer was

no longer able to produce documentation

to show conclusively that he was short

changed. In many other instances, my

Investigation revealed, the subscriber

never discovered that an unscrupulous

magazine salesman had entered the subscriptions for shorter periods of time

than the subscriber's contract called for,

and than he had paid for.

For these reasons, in a letter dated October 29, 1969, I urged the Magazine

Publishers Association to take voluntary

action to initiate open subscription dating. During the intervening period, my

office had a series of contacts with MPA

about this matter and I am pleased-. to

report that I was notified this week that

CONGRESSIONAL RECORD — HOUSE June 1' Q, lc''' .

MPA has established voluntary "Guidelines for Magazine Subscription Fulfill-

,„ment and Service Practices" which consists of a series of recommended procedures which, if widely implemented by

Industry members, has the potential to

achieve a commendable goal of "Truth

in Subscription Selling." Already, onethird of the MPA members have adopted

the guidelines.

Having been critical of MPA in the past

for what I felt was a failure or reluctance

to deal with abuses occurring in the

marketing of periodicals published by

MPA members, I want now to commend

MPA for devising a set of guidelines

which go to the heart of many of the industry's service problems.

The guidelines provide, for example,

that—

Subscription service for weekly or biweekly publications be initiated within

25 days after receipt' of the order by the

publisher.

Subscription service for monthly or

less frequently issued publications be initiated within.45 days after receipt of the

order by the publisher.

When the publisher cannot meet the

deadlines to start service, a written notice of the delay advising of the expected

starting date of service be sent to the

subscriber.

Recipients of gift subscriptions be sent

timely written notice identifying the

donor, unless the donor has given specific

instructions to the contrary.4

Subscribers be notified in wr„:r.',;in

the event service has been, or wLi be, interrupted by the publisher for any reason, arid that the notice include information as to steps taken to insure

subscriber will receive the full number

of issues to which he is entitled.

Mailing address labels will include the

subscription expiration date in a manner

that will be easily identified arid readily

understood by the subscriber.

A change of address form or adequate

instruction for the subscriber to ef.:ect

such change be provided periodically in

the magazine.

The publisher will process address

changes promptly an make all reasonable effort to maintain continuous service.

The publisher will make all reasonable . .

effort to answer consurr• conva..;,ints

and inquiries within 15 day6 of their receipt.

Still other aspects of subscrion servicing are given attention in the guic:alines, a copy of which I will ask to Le in-
26

:eluded in the RECORD with my remarks.

Certainly, if the INTA member publishers Will voluntarily adopt these guidelines arid make an honest and forceful

effort to comply with the pr1po3zd time

limits for service starts and for responses

to consumer complaints and inquiries,

the magazine tidustry will have taken a

tremendous stride to restore consumer

confidenee.

I also am pleased to acknowledge and

ask to be incorporated in the CONGRESSIONAL RECORD the results of a survey of

subscription dating policies of periodical

publishers initiated by iVf2A's Central

Registry of Magazine Subscription Solicitors in response to my request for voluntary open subscription dating on magazine mailing labels. This report identifies some 250 periodicals and reveals how

coded Subscription expiration dates can

be read.

Among those which a-cready • have

adopted open dating is Rea r.e.r's Di2,-est

Some 6 months ago a member of my

staff met with Coleman Hoyt, of Reader's Digest, and Norman S. H.alliday,

vice president of MPA, to discuss magazine sales practices and to suggest that

Reader's Digest, the periodical with the

largest mail circulation, adopt open subscription dating on its mailing labels. I

am gratified that Reader's Digest has

taken this step.

In addition, although they are not listed among the periodicals in the 212,-.',.%

compilation, I have noted that several

consumer-oriented periodicals utilize a

dating method that can be read by the

average consumer.

The Changing Times code line begins

with the month and year in which the

subscription will expire, as follows:

IFEB72] R462311H8EPU612R92741 (February, 1972)

The Consumer Reports mailing lz.bel

identified the month and r:;,1*by ;,--urabers which appear near the end of the

code line, as follows:

11004527 N 1[057113 (May, 1971)

•

In conclusion, Mr. Speaker, i;cw

steps by the magazine industi.;:

prove customer service and provitio.

cits,ur.er with the in•.:ormation he needs

cietermine, with eohildence, that he is

receiving the subscription service for

which he has paid and to which he is

;entitled are deserving of public attention.

urge every publisher to consider care-

• the voluntary adoption of the MPA

aielines in order that "Truth in Subserition Selling" will 'become an industrywide reality.

I invite the attention of my colleagues

to the :-.?:uic,elines, and the key for reading sul;scription dates on mailing labels,

as well aa correspondence which relates

to the development of both:

OcTosER 29, 1969.

Mr. STEP:AE:1 E. KELLY,

President, Mayaz:ine Publishers Association,

New York, N.Y.

DEAR. STEVE: This is to express my appreciation for your obvious concern and your

continuing ef;orts to correct some most

serious sales abuses which have been identified with some magazine subscription agencies engaged in cash and PDS door-to-door

I was particularly pleased to receive the

report on efforts by the Magazine Publishers

sociation and Central Registry to combat

such abuses. While I remain convinced that

many of the abuses I have been able to docuMent are too serious to be overlooked by

the Federal agencies which have authority

to intervene, I have been favorably impressed

by concern being demonstrated by MPA.

In this regard, I commend the action of

the MPA's Executive Committee proposing

an amendment to your by-laws providing for

removal :rorn membership in the Association

of any member who has been found to have

repeatedly conducted its business in violation of law or of the written standards prescribed for the industry by your Association.

Its prompt approval by your entire membership must be viewed as an act of good faith

on the part of a majority of publishers, particularly if its authority is exercised when

necessary in the future. I hope you will convey my comments to the MPA membership

dul•i:c; your November 6th meeting.

Further, there appear to be at least two

other areas in which the publishers themselves could be instrumental in helping to

halt certain practices which are being used to

deceive subscribers. In these practices, deception is possible because the subscriber is

unable to read coded information on mailing

labels which would reveal when a subscription is due to expire. The consumer thus

cannot determine whether a subscription

purchased through a sales agency has been

entered with the publisher for the period

of time covered in his contract.

I ask, therefore, that the Magazine Publishers Association consider industry-wide

action to clearly identify on the mailing

label of each periodical the month and year

the subscription is due to expire. Some periodicals already follow such practice and I

wholeheartedly urge all publishers to implement this form of expiration date identification.

Further, a great deal of further confusion

could be avoided for consumersand the industry alike if these same mailing labels with

expiration date clearly identified were made

an integral part of the mail-in subscription

renewal forms which publishers mail to their

subscribers. Because of the practices of some

publishers to make mass mailings of sub-

:cription renewal solicitations several times

each year, whether or not the subscriber's

current subscription is due to expire, I believe the subscriber deserves fair warning if

his suoscription is not about to expire.
27

Although legislation could accomplish disclosure of expiration dates, I believe that the

Magazine Publishers Association may wish to

consider implementing this practice as another step to 2reserve the integrity of the'.

magazine industry from further exploitation

by those who engage in unscrupulous or unlawful practices.

With warm personal regards, I am,

Sincerely yours,

FRED B. ROONEY,

Member of Congress.

MAGAZINE PUBLISHERS ASSOCIATION, INC.,

New York, N.Y., March 13, 1970.

Hon. FRED B. ROONEY,

Congress of the United States,

House of Representatives,

Washington, D.C.

DEAR FRED: Here is the information I discussed with you on the telephone thc other

day in answer to your letter of February

25th.

As I reported, we did make a survey of

the extent to which the expiration datc now

appears on the address labels of subscription copies of magazines. You will be interested to know that for 92% of the 203 magazines for which we received replies, the expiration date is shown someplace on the address label. At the same time, Fred, in many

cases it may be indicated in a line with other

information and therefore a little difficult

to read readily. To study this further, we

have appointed a special committee to study

and set up guidelines for fulfillment procedures and to make further recommendations

for the industry in line with your comments

and suggestions. (The committee has already

had a preliminary meeting too, you'll be glad

to know.)

Concerning an agency's participation in

the Central Registry program as stated in

the Articles of Agreement for the Cash

Agencies, "any field selling subscription

agency . . may become a party to these

Articles of Agreement upon approval of the

Cash Section at a duly called meeting provided there is evidence before the Cash Section of the ability of the agency and its principals to conduct its business of soliciting

magazine subscriptions in accordance with

the purposes of these Articles of Agreement."

The same criterion of evidence of ability to

meet the Standards set forth applies to participation in the PDS Code program too. As an

aid to determining this ability to comply, a

questionnaire form is mailed to each agency

applying for participation. I am enclosing

a copy of this questionnaire and I think you

will find it self-explanatory. (If the person

requesting this information has any other

questions, have him get in touch with Bob

Goshorn.)

It goes without saying that we're following through on all the reports you forwarded

to us, and we appreciate your making the

Information available so that we can be a

such assistance.

Cordially,

STEPHEN E. KELLY,

President.

MAGAZINE PUBLISHERS ASSOCIATION, INC.,

New York, N.Y., June 9, 1971.

Hon. FRED B. ROONEY,

U.S. House of Representatives,

Cannon House 011ie.,Building,

Washington, D.C.

DEAR CONGRESSMAN ROONEY: The enclosed

two reports I think will be of interest to you

in light of your concern about subscription

mailing labels and the expiration date

thereon. The "Guidelines" were completed

last winter and sent out to our members.

, Participation in them is on a voluntary basis

and to date approximately a third of our

membership has adopted them. Expiration

dates are dealt with on page four under point

B (2).

Also enclosed is a recent report out of our

New York office cataloging the various publications, the form of their mailing labels and

how the expiration date may be detemined

from those labels. As a result of a conversation Ray and I had with Coleman Hoyt of

the Reader's Digest earlier this yea-. Digest label, page 20, clearly sets forth ils expiration date.

If you have any questions about this material, please let ate know.

Sincerely yours,

NORMAN S. HALT:zeal'',

Vice President.

[From the Magazine Publishers Association,

Inc. j

GUIDELINES FOR MAGAZINE SUBSCRIPTION

FULFILLMENT AND SERVICE PBACTICiz;S

INTRODUCTION

The purpose of these Guidelines for Magaz.;10 Subscription Fulfillment and Service Is

to establish standards to provide for custxs-ner satisfaction, to maintain the good will and

confidence of the public and its willin,glies;.

to enter into subscription contracts, and to

forestall subscriber discontent and adverse

publicity.

The following Guidelines are therefore se;

forth for voluntary adoption by those publishers desiring to conform to ;hese standards.

A. PROCESSING OF SUBSCRIPTION ORDERS

1. Start of service

The publisher will promptly process all

subscription orders received, and will make

every effort, unless otherwise requested by

the subscriber, to insure the mailing of the

first issue to the subscriber within the following periods:

(a) For magazines published monthly or

less frequently; the first copy will be :nailed

within forty-five (45) days after receipt of

the order by the publisher.

(b) For magazines published weekly or biweekly, the first issue will be rr.:-.1:ed within

twenty-five (25) days after receipt af the

order by the publisher.

The publisher will make every effort to see

that its authorized subscription agencies

transmit orders promptly to avoid delay between the time the order is given by the

subscriber and the time it is received by the

publisher.
28

, 2. Notice of delayed start

In the event the publisher Is unable to

mail the first issue within the above time

limits, a written notice of the delay will be

sent to the subscriber within the time limits

set forth in paragraph 1 above informin;; hini

of the starting issue or expected mailing di.: to

of the first issue. If for any reason this now

date cannot be met, the publisher will again

notify the subscriber in writing. These written notices will continue to he sent until

the first issue is mailed. The publisher will

also make all reasonable effort to see that

such notification is readily identifiable by

the subscriber as pertaining to the subscription already ordered.

3. Gift subscriptions

The publisher will send or cause to be

sent timely written notice to all recipients of

gift subscriptions of the gift and the name

of the donor, unless specific instructions to

the contrary are received from the donor.

4. Sequence of copies

When a new subscription is started with an

issue dated prior to the issue currently on

sale, in the absence of specific request by

the subscriber, the publisher will make all

reasonable effort to adhere to the following

conditions; to the extent that his fulfillment

operation makes such compliance feasible.

(a) The publisher will comply 'with the

Bylaws and Rules of the Audit Bureau of

Circulation governing "back copies." [3:fl

summary, these Regulations limit the service

of back copies as net paid circulation, (unless the subscriber is otherwise notified in

advance of the order) to no more t.n two

issues previous to that current at the a ace

of the order in the case of weekly publications and not more than one such previous

issue for other publications.]

(b) All copies will be sent to the sub-

.: ariber in chronological sequence of issue

<alto.

(c) If a subscription has been started with

back issue, only one issue of a magazine

will be sent to the subscriber at one time.

(d) If more than one "back issue" is to

sent in servicing the order, the following

szlie.dule will be used in mailing the next

copy to the subscriber:

For magazines published monthly or less

f:equently, the second copy will be mailed

no sooner than seven (7) days after the first

!-313Y.

' For magazines published weekly or bi-

.se.tly, the second copy will be mailed no

,00iier than three (3) days after the first

'copy.

5. Zec.;:uest for specific issue

' If a request is made by the, subscriber or

i..rency to start service with a particular isall reasonable effort will be made to

comply with such request. If such request

zanno; be fulfilled, the publisher will notify

the subscriber or agency of the reasons for

inability to comply with it and of the

issue with which service is being started.

B. SUBSCR=ION SEUVICE

1. :ntcrruption of service

The --,u1;11,he: will notify the subscriber

w:iting in the event service will be, or

s been, interrupted by the publisher for

any reason. This notice will inform the sub-

:.,cr.ber of ;he provision made to insure that

110 will receive the full number of copies to

w:aich he is emit-ed.

2. iration date

The mailing, address labels will include

the subscripi,ion expiration date in a mann::: which will be easily identified and readily

understood by the subscriber. The publisher

will take whatever steps he deems necessz..ry to provide an explanation of how the

expiration date is shown.

3. Changes of address

The publsilaer will include in his magazine periodically a subscriber Change of Ad'

cress form and/or adequate instructions for

the subscriber to effect such change, to

facilitate prompt and accurate handling of

such requests.

The publisher will process changes of address promptly upon receipt, and make all

reasonable effort to maintain continuous

service to the subscriber when the subscriber gives ample notice of the effective date

of the address change. In any event, unless

otherwise requested, the first copy mailed

to the new address will normally be within

the time limits set forth in paragraph A 1,

above for the start of new subscriptions.

C. RENEWALS

1. Continuity of service

The publisher will process all renewal

orders promptly as they are received, and

will make every effort to avoid a break in

service provided the renewal is received in

reasonable time of the expiration date.

(a) On renewal orders for schools, libraries

or other institutions where there is reason

to believe that a complete file of the magazine may be desired, the publisher will make

such special effort as is reasonable to maintain continuous service.

2. Form of renewal offer

Renewal notices will be clearly recognizable as solicitations for subscription orders

and will not be of a format such as to mislead the subscriber or give appearance that

it is simply a bill or invoice.

D. SUBSCRIBER INQUIRIES

1. The publisher will make all reasonable

effort to answer subscriber complaints, inquiries, or requests for information concerning their subscriptions within fifteen (15)

days after their receipt. (It is recognized,

however, that some subscriber questions will

have already been resolved by the time the

inquiry reaches the publisher, and may not

require an answer at that time.)

2. The use of form letters or postcards to

answer or acknowledge correspondence or

complaints is permissable as a means of expediting service.

E. ar.vizw OF GUIDELINr.3

1. These Guidelines shall be reviewed by

the Circulation Committee of the Magaziae

Publishers Association as it deems proper

from time-to time or upon request of three

or more signatory publishers, in writing to •
29

'the Chairman of the Circulation Committee,

2. Any proposed charces in the Guidelines

will be efrectivo upon approval by a raa,ority

of the Cifculation Committee.

F. ACCEPTANCE OF GUIDELINES

1. Acceptance of these Guidelines by publisher-members of the Magazine Pu.ers

Association shall be on a Voluntary basis.

(a) Any publisher may now or here Cr

formally accept these Guidelines by

In writing the President of the Mazazirio

Publishers Association of such intent.

(b) A publisher, having formally accept:el

these Guidelines may withdraw from the obligations assumed thereby by similarly ottfying the President, in writing of such

2. A list of publishers formally accapinz;

these Guidelines will be available for di.;-

tribution at the discretion of the Prcsident

of the Magazine Publishers Association.

• 1VIAGAZT.NE PUDLISIIEIIS •

Assoc.:A./7°x, 1-1cc..,

New York, N.Y., April 30, 1,77.

Memorandum to: Principal of All liaencios

Participating in tile Central aei,-istry

Program.

From: Robert M. Gcsborn.

Subject: Subscription expiration dates.

As a by-product of a study we recently

made concerning notice of expiration cla.;es

on subscription labels, we developed tbe

closed information on how various publishers show the expiration date.

We though this information might be

helpful and of interest to you, • and are,

therefore, forwarding it to you at this time.

If any major publication does not appear,

it may be assumed it did not •respond to

our questionnaire.

HOW TO READ SUBSCRIPTION EXPIRATION DATES (EXPIRATION PORTION OF CODE IS ENCLOSED IN BRACKETS

[Compiled by Magazine Publishers Association]

Mazazine Label Explanation

trLcts and bibliog. PA 19007 ROHROHM[NO] CDA 209

rapny.

Advertising ayeAlr Progress 9&2607500 571001PA420 [JAN711 

American Artist

American Girl 

15th & 16th digits in Code

line show ex date. Example: 13=January 1973,

59-June 1969 (7), NO

November 1970.

AA IMAR71] Self-evident.

Self-evident.

AADESPECASUUNISZO A [JUL711 ..... Self-evident.

Ex date at end of subscriber

Mrs. John Doe [G711 name line: months coded

A thru M, omitting I,

followed by year; i.e.,

A71, H71, J71=January,

August, September 1971.

Arr.:rii;an Heritage B70302AAMSJ90206H4[16910L181H 19th, 20th & 21st digits in

code line show ex date:

months coded A thru L,

followed by year; i.e.,

A71, D71, L71=January,

April, December 1971.

Ex date shown in code line:

i.e., A6 is month and

year of starting date

(Apr. 1966), F7 is ex

date (Feb. 1967).

American Home Label sample not furnished. Example givon: "John

Smith SEP"—Expire

month. "E 70"—Expire

year, may be reversed:-

07. •

Amer!can History

Illustrated.

2A A6[F7] 

American Medical JA 16 R K E1215 [M71] D 12th, 13th & 

Association, Journal in Cede line Show ex'

of the date. Months coded

thru M, omitting

lowed by year—A71,

. H71, M71..January,

Au -ust, Nu:mbar 1971.

American Naturalist.... PA19007 ROHROHM[NO1 AN 15th 4'. 16th dits in Code

line show ex data. Examples: 13-January

1973, 59=June 1539 (7),

NO=November 1970.

Ex date may be ascertained

by writing to the JournaL

American Optometric Label sample not furnished 

Association, Journal

of the
30

Magazine Label Explanation ,

American School Board 0591740SLZK440J9G 3 0126 [511 Last two digits in code line Journal show ex date. Mo•Itils

shown, Jan. thru Oct. as

1 thru 0, Nov. is -,

Dec. is +. I.E., 51=May

1971, -0=November

1970.

Amusement Business... BBDNGOLD121JORSZ640[011169003012_. 20th, 21st & 22nd digits

in Code line show ex

date: year 0 thru

week 1 thru 52-i.e.,

011-11th week in '70. Analog 321100 KN1 00190093 [0EC721 1 L Self-evident.

Antiques AN [12-711 RS12 0M6254 first throe or lc.-

following tikk a, :

(AN) show mon,,i year •

cf ex date.

Archives of Derma- 14 A 0239125015 [G71] N 14th, 15th & 16th digiZ3 in

to logy. Code line show ex Oata.

Months coueci A thru M,

omitting i, fdiow ha

year-A71. 071.

January, Jay, Decemder

1571.

Archives of ZnvIron- 32 A 0240163028 1A711 D 14th, 15th & 16th digits in

mental Health code line show ex date.

Months coded A thru M,

omitting I, followed by

year-A71, 071, M71=

January, July, December

1971,

; Archives of Genera, 41 A LOUIS101 W1M711D 14th, 15th & 16th digits in

Psychiatry code line show ex date.

Months coded A thru M,

omitting I, followed by

year-A71, G71, M71==

January, July, December

1971.

A, ,c,s of Internal 50 A ST VIBARRS, [M701 D 141h, 15th & 16th digits in

Medicine code line show ex date.

Months coded A thru M,

omitting I, followed by

year-A70, G70, M70=

January, July, December

1970.

Arch.ves of Neurology... 59 A CHARL811 A 1G711 D_ 14th, 15th & 16th digits in

code line show ex date.

Months coded A thru M,

omitting I, followed by

year-A71, G71, M71=

January, July, December

1971.

'Archives of Oththal- 68 A 0050265018 1G721 D 14th, 15th & 16th digits In

mazy. code line show ex date.

Months coded A thru M,

omitting 1, followed by

year-A72, G72, M72=

January, July, December

1972.

Archives of Otolaryn- 77 A 0351568035 [F711 0 14th, 15th & 16th digits in

gology. code line show ex date.

Months coded A thru M,

omitting 1, followed by

year-A71, F71, M71=

January, June, December

1971.

Archives of Pathology... 86 A 01102690601E72[ D. 14th, 15th & 16th digits in

code line show ex date.

Months coded A thru M,

omitting 1, followed by

year-A72, E72, M72=

January, May, December

1972.

Archives of Surgery 95 A 0470568053 [L71] D 14th, 15th & 16th digits in

code line show ex date.

Months coded A this M,

omitting 1, followed by

year-A71, E71, L71=

January, May, November

1971.
31

Label Explanation

Argosy 27004 WLS 1003S093 [FEB711 A 6 Self-evident.

Astrophysical Journal__ PA19007 ROHROHM [NO1 AJ 209 15th & 16th digits in code

line show ex date. Examples: 13=January

1973, 59=June 1969 (7),

NO= November 1970.

Astrophysical Supple- PA19007 ROHROHM [NO1 AS 209 15th & 16th digits in code

ment Series, line show ex date.

Examples: 13=January

1973, 59=June 1909(7),

NO= November 1970.

Atlantic Monthly AM MRC2GE520A019 3 [12691 Last four digits in code line

show ex date: first two

show month, last two

show year.

Atlas 580004 118 OAAPEN94 [FEB721 1 16____ Self-evident.

Aud:o A [NOV711 OK-17 Self-evident.

Baby Talk 12-70-[11-711 Code line at top shows

month and year of start,

followed by month and

year of expire.

Banking, Journal of the 51 9990012882 [06701 017 13th thru 16th digits in

A.B.A. code line show ex date:

0670=June 1970.

Better Homes &

Gardens.

1-110400TA12-1-35991 [FEB711 Self-evident.

Bil.00ard BBDNGOLD121JORSZ640[011189C03012... 20th, 21st and 22nd digits

in code line show ex

date: year, 0 thru 9;

week, 1 thru 52.

Back World. X3841C0THM155385683 [09/711 2 Self-evident.

Boating. Label sample not furnished Ex date shown in clear

typo two digits in from

end of code line: i.e.,

JUL70.

Botanical Gazette PA19007 ROHROHM[N01 BG 209 15th & 16th di;;:; ;

tine show o•,:-

13=.;

59=June „

November 1570..

Boys Life AAC 6456 ZGLR11771 0 16610611 Last three digits in code

,irie show ex dote: i.e.,

66 =J u n e, 1 =1971.

Bride's magazine, the... 00094091 55.073 FE123 1 j371) Last three digits in code

line show en zinte: 151

sows month, Ful,.,

arch, flay, ;tine., ,ug.,

Sept., Nov., Dec. numbered 1 thru 6; last two

show year.

Bulletin of the Center PA19007 ROHROHMINO1 CB 209. 151U & 16th digits in code

for Children's Books. iine show ex li;te.

Examples: lli=i:,,-,:;;•,-•

1973, 59=Jone 15.•::: ?),

NO=Noven-ii,er 1970.

Business Management.. Label sample not furnished Ex date not shown.

, Business Week 0620 _EPE999 99DA [DEC70] Seif-evident.

1

Camping Journal 15 63 8260 BDR146AWW-3 [APR711...... Self-evident.
32

Magazine Label Explanation

Car & Driver Lai)el sample not furnished Ex date shown clearly two

digits in from end of code

line: i.e., JUL71.

Car Craft 7420107;; •10011111 179121 Ex date shown in last four

digits of coda line: first

two show year, last two

show month—Sarn?ie

shows December 1979.

Cat Fancy Label Sample not furnished Example given:

"John Smith SEP"—

expire month.

"E 70"—expire year; may

be reversed: 07.

Catholic Digest 3 206220JHN3T-981 [APR711 Self-evident.

Chicago Label sample not furnished Ex date not shown.

Child Development PA19007 ROHROHMINOI CD1 209 15:n & 16th digits in code

Journal. • ;ine show ex date.

Examples: 13=January

1973 59=june 1959

(7), NO= November 1970.

Children's Digest - 5764 AKN 15 0KL123 61251 Last two digits in code line

show issue number of

expire. Issues numbered

consecutively and #

snown on contents page.

25=February 1573.

(Starting in 1971, ex

data will be shown as

c. F6373.)

Christian Herald CH HILL92*TURGZ4 170111 1 Last four digits but one in

code line show ex date.

First two show year,

last two show month:

7011 =November 1970.

Christian Herald ITALYEERGAXXP0112040Al2RA 10311... Last three digits in code

line show ex date.

Months coded 01 thru

12; years 0 thru 9.

Christian Life ITALYEERGAXXP0112040Al2RA 10311_ Last three digits in code

line show ex date: i.e.,

031=March 1971, 121=

December 1971.

Christianity Today Juanita Sue Harper [1-741V Ex date shown at end of

subscriber name line:

i.e., 1-74=January 1974.

Cincinnati Label sample not furnished Ex date not shown.

Civil War Times 2A E6-[F71 Ex date shown in code line:

Illustrated. i.e., A6 is month and

year of starting date

(Apr. 1966), F7 is ex

date (Feb. 1967).

Classical Philology PA19007 ROHROHMINO1 CP 209 15th & 16th digits in code

line show ex date. Examples: 13=January

1973,59—June 1E69(7),

NO=Novemi/, 1573.

Coast Label sample not furnished Ex date not shown.

Commonweal., =61193 [5-711. , Last 6igits on code line

- .. -,x date: i.e., 5-71.,

: 1071.

Comparative Politics.... PA19007 ROHROHMiN01 COP 209 151h & 16th digits In code

line show ex date. Examples: 13=.1anuary

1673, 99—June 1569

(7), liO..liovember

1970.

Connoisseur GHIDEC69110000 00 ABC005 000098 Self-evident.

Cosmopolitan CM[OCT72110001 03 RCH2HY 461195_... Self-evident.
33

.azine Label- Explanation

R.1995039-S;B-JAN 721 RI 11th digit in code line

shows week of ex data

(A thru E for 5 weeks),

month and year are

self-evident.

Label sample not furnished Ex date shown in clear type

two digits from end of .

code line: i.e., "JUL70."

.)aeua:us [3-721 Ex data shown above subscriname: quarterly1 =winter, 2 =spring,

3 =summer, 4 =fall,

followed by year.

diseas,-,.: a: Cnildren, 23 A 0270164012 1H711 N 14th, 15th & 16th digits in

Arne:icon Journal of. code line show ex date.

Months coded A thru M,

omitting I, followed by

year: i.e., A71, E71,

H71=January, May,

August 1971.

Dog Fancy Label sample not furnished Example given: "John

Smith SEP"—Expire

month.

"E 70"—expire year, may

be reversed: 07.

Eao.ly X384100THM155385683 [09/711 2 Self-evident.

Develcoment PA19007 ROHROHM [NO! ECO 209 15th & 16th digits in code

and Cultural Cnange. line show ex date.

Examples: 13=January

1973, 59 =J une 1969 (7),

NO = November 1970.

::ectronics lilustrated_._ 57 58 6596 SLE-8TPH-1 11%041 Bi-monthly, and last five

digits in code line show

number of subsequent

issues coming: i.e.,

ITGO4=4 issues to go.

Eierantary Electronics__ 12 46 1590 BAR30IELT-5 [ITG121 Last five digits in code line

show number of subsequent issues to come:

i.e., ITG12=12 issues

to go.

Clunentary School PA19007 ROHROHM [NO! US 209 15th & 16th digits in code

Journal, lino show ex date.

Examples: 13-January

1973, 59 .=--)une 1969 (7),

NO=November 1970.

Elks magazine, the Label sample not furnished Ex date not shown.

Ellery Queen 15 88 8260 CHU563MRW-0 [APR711 Self-edvident. -

Episcopalian, the PTOD110SYLM9 [JAN721 11001 Self-evident.

Esquire__ 460014 LNG 6750G098 1SEP711 1 Q- Self-evident.

Eternity BHE 52 LIVR9 11 1lAN711 000 Self-evident.

Z.thics PA19007 ROHROHMINO1 ET 209 15th & 16th digits in code

line show ex date. Examples: 13 =January 1973,

59 =June 1969(7), NO

November 1970.

Cxchanze,ihe [111907751[691. First two digits in code line I

show ex month, last two

show year: i.e., 11 

69= November 1969..

Handyman., T118' GP196897 11291 Last three digits in code.

line show ex issue number, which appears on

contents page.

Family nealth 580004 PRI 1271A09 [DEC701 1 D Self-evident.
34

Magazine Label , , Explanation

Farm Journal 1BBA 60904202WLEME 9 [C741___ Last three digits in code line

show ex- date: months

coded A thru L. I.e., C74-=

March 1974.

Fate BLB4377RPO 01081 12112441 2 Digits indicated show ex

issue number; issue

number appears on Mierpage; subscribers are

-given this info upon

inquiry.

Field & Stream 64 84 6640 MEYBX140G-9 [NOV711 Self-evident.

Financial Executive [04/711 MC. s-08769 3. Self-evident.

Financial World FW MSS3AG 371019 C7010771; Last four digits 'on code

show ex auto, month and

year.

Flying Label sample not furnished Ex date shown in clear type.

two d.i.dts in from cod of

— Code line: i.e., JUL.70.

Forbes ' 1234'...,..73 DP1 1DEC711 SelkividenL ., .,

e 

Fortune [JUN71] BOW SN400091Y59 40 a Self-evident

Gentlemen's Quarterly... 460014 LNG 67500098 1SEP711 1 Q.....,„„Sf,-;evident.

Gift & Tableware BBDNGOLD121JORSZ640[0111B9C03012.. 20th; 21st ancl 22n4 digits in

Reporter.. ,,/ , Code lino show ex (rale:

:year (0 thru,9), month -

.(1 thru 12); 

.

Glamour Zi21100KNI 0019G093 [SEP751 1 8 Self-evident.

Golden Lo.)ol sample not furnished Ex date appears as figures

at end of addressee line:

i.e., (12-63).

Golf • G126 RF726967 [1491 Last three digits in code

line show issue nun.

ber. (No explanation

where it appears in

magazine—not on con-

- 

tents page.)

Golf Digest 362228 SND 00126096 [JUN711 7 D Self-evident.

Good Housekeeping,....._ GH[APR71] 10001 03 RBI2RG 862192._ Self-evident

Gourmet Q0MC09 10 MD2BA2 69 11741 Last three digits in code

lino show ex issue

number. (Chart furnished

showing example to be

Juno 19/1.)

Grade Teacher... EGLI 168 OCE J HEA19 [9701 01 Ex data shown in three

figures, two digits in

from end of code line:

i.e., 970=September

1970.

Guns & Ammo 7420TZM *10011111 [7912]' Last four figures in code

line show year and

month of ex date-: i.e.,.

7912-1979, Dec.

, Hairdo HA FRD46T538A059 0111071] Last four figures in code

1' 

line show ex date: i.e.,

1071=October 1971.
35

.4bal Explanation

Rarpers HB[DEG711 10001 03 PWE2RY 481894... Self-evident.

Harper's HM POR2SE400R089 1 108751..__..------ Last four figures in cods

line show ex date: i.e.,

0875= August 1975.

Harvard Business Re- Label sample not furnished. Ex date not shown.'(Will by view. . changed to positive indica-

(ion in 1971.)

High Fidelity HFOALUCZ4**MCBRZO A [MAR721 Self-evident.

Highlights for Children .... 2 [DEC711 S0WR2X7197 SZ Self-evident.

His _ SAMPLM34225815Q[9701AATC1 ,69A.____ 21st 22nd & 23rd digits in

code we shaw cix date: 1

thru this Juno, 7,

8, 9=Oct., Nov., Dec.,

plus year. I.E., 970-Dec.

1970.

History of Religions PA19007 ROHROHMINO1 HR 209 15th & 16th digits in coda

line show ex date. Exampies: 13=Janu3ry 1973,

59=June 1969 (7), NO=

November 1970.

Home Garden'. 330004 HJK 063611097 [NOV711 AG Self-evident.

Home magazine Not mailed Single-copy salest only.

Horizon 880302AAMS.1902061i4116910L181H 191n, 21.,tri .1 21st digits in

...- .... code line show ex ciate:

• months coded A this L:

i.e., A7i, 071, 171-Jan.,

Apr., Oct. 1971.

Kot Rod.. 7420TQM *10011111 [79121 Last four figures in code line

show year and month of ex

date: i.e., 7912=1979,

. Dec.

Haus° & Garc.,n_______ 321100 KN I 0019G093 :SEP751 "1 5 Self-evident.

, House Beautiful liFISEP721 10001 03 PTT5RG 500894------Self-evident.

I ..lumen . Genetics, PA19007 ROHROH WOG; GE 209 15th & 16th digits in code

; American Journal of. line show ex date. Ex- •

amples: 13 =January

' 1973, 59=June 1939 (7),

NO = November 1970. i-..-npfy Pumpty 573 & WRT 15 0H1123 C[951 Last two digits in code line

show ex issue number.

(Sometime in 1971 ex •

. date will begin to appear

clearly: i.e., JUL71.)

income Oppor:unities.... 14 44 4880 TH0505DS1-6 [ITG04] Last five digits (ITG04)=

"Issues To Go 4."

Industrie: Arts and 10428-9-51095-2-1-j1001-A Last three numbers in code

Vudational Education. line show month and year

of ex date: i.e., 100=

October 1970.

Ini,enue IN KNN47H643L099 01 [07721 Last four figures in code

line show ex date: i.e.,

0772=July 1972.

. X5841—THM155385683 ;09/7112_ ..... Self-evident.
36

Magazine Label Explanation

to..rnal cif Aertising Label sample not furnished Length of subscription shown

i,esearch. • by volumes covered: i.e.,

8/9/10-1-2 shows to receive all of vols. 8 and 9

and 1st 2 issues of 10.

oi Business PA19067 ROHR0HM1N0IJB 209 15th & 16th digits in code

line show ex date. Examples: 13=Janaury

1973, 59=June 1969 (7),

NO = November 1970.

Journal of Cege Label sample not furnished Ex date not shown.

Placement.

Journal of Geology PA13007 ROHRO1-tM[NO1 JO 209 15th & 16th digits in code

line show ex date.

Examples: 13=January

1973, 59=June 1959 (7);

NO=November 1970.

Journal of Infectious PA19007 ROHROHM1NO1 JID 209 15th & 16th digits in code

Diseases. • line show ex date.

Examples: 13=January

1973, 59=June 1969 (7),

NO= November 1970.

Journal of Modern ?A19007 ROHROHM:NO1 MH 209 15th & 16;3 digits in code

history, line show ex date.

Examples: 13=January

1973, 59=June 1969 (7),

NO=November 1970.

of PA19007 ROHROHN11N01 NE 209 15th & 16th digits in code

Stuoies. line show ex date.

Examples: 13=January,

1973, 59=June 1969 (7).

NO—November 1970.

Joornal of Political PA19007 ROHOHMINO1 PE 209 15th & 16th digits in code

Economy. line show ex date.

Examples: 13=January

1973, 59=June 1969 (7).

NO=November 1970.

Journal of Religion PA19007 ROHROHM[NO1 RE 209 151h & 16th digits in code

line show ex date.

Examples: 13—January

1973, 59=June 1969 (7),

NO=November 1970.

Ladies Home Journal__ Label sample not furnished Example given: "John

Smith SEP"—tx

month. "E 70"—Ex

year; may be reversed07.

Library Quarterly.... PA19007 ROHROHMINO1 LQ 209 15th & 16th digits in code

line show ex date.

Examples: 13=January

1973, 59=June 1969 (7),

NO= November 1970.

Life [00711 DGA CA018H99L50 23 55 Self Evident. (Months

abbreviated as JA, FB,

MR, AP, MY, JE, IL.

AU, SE, OC, NO, DE.)

Look P1161458 5 [6-751 Self-evident..

Look—Top/Spot. '8004 ROE 02107093 [AUG701 N 2 Self-evident.

Lutheran, the 1:.0 NON 14 11101101 6 Last four digits, but one, of

code line show ex date:

month and last figure of

year. 0110 = January

1971.

Maaadden-Bartell (ali Ex date month shown at

publications) end of subscriber name

fAl line, year at end of ad-

() 1271 dress line. Months coded

........ A thru M, omitting I.

(Year figures reversed)

' Mademoiselle 32,1100 KNI 0019G093 [SEP751 3 9 Self-evident.
37

MaZeZini: Explanation

Marketing Communications

Ex date shown ai end of

[12711 C s,:bscriber namo

1271 = December 1971.

Marriage C [0-711 • Ex date shown c t lay righ1.

oa top line; nionths coded.

1 thru 9 for Jan. ti-.rd

Sept., 0, N, D ;or C., -A.,

Nov., Dec. D-71 = December 1971.

McCall's 5Al2G72901BAC5GEI803901V14082 [8721_ Last three digits in corR,

line show ex date; mcnths

coded 1 thru 9 for Jan.

thru Sep., 0, N, D for

Get., Nov.,

Dec. 872 = Auusl 1972.

Mechanical Translation PAIS007 ROHROHM [NO[ MT 209 15to & 16th dizits in code •

line show ex data. Zxamples: 13 = Janary

1973, 59 = June 1969

(?), NO = November

1970.

Mechanix Illustrated__ 88 89 7980 BYR304MC1-8 [APR741 Self-evident

Merchandising Week BBDNGOLD121JORSZ64010111B9C03012.. 201h, 21st & 22nd digits

In code line sho\

data: year (0

and week .(1 taro '52).

Midway 0A19007 ROHROI-IM[NO1 MI 209 15th & 15th digi1s in code

line show ex data.

Examples: 13=jarz,r/

1973, 59=juno 1939 (7),

NO= November 1970.

Model Airplane News... Label sample not furnished "Expires DI (December

(D) 1971 (1)."

Modern Bride. Label sample not furnished Ex date shown clearly

two digits in from end

of code line: i.e.,

"JUL73." -

Modern Manufacturing._ 017ZOSIT411MAJAI [MAR72I Self-evident

Modern Packaging Label sample notfurnished Ex date not shown.

Modern Photography__ MPDBSCOT666THERZ2 A [FEB72I Self-evident.

Modern Romances__ MR ALE213307M089 01 [10711 Self-evident

Modern Screen MS SRI7BX421T019 01 109711 Self-evident

Monographs of the Srcd. PA19001 ROHROHM[NOI MON 209 15th & 18th digits in coda

line show ex c:ata.

Examples: 13=Jcncary

1973, 59=June 1930 (7),

O= November 1970.

Moody Monthly, Self-evident

Mrs John Smith [NOV711 

Motive Self-evident.

COUN LAY LIFE & WORK [07/711 

Motor Boating & Sailing_ MBIMAR721 10001 03 PRK3MS 730198._ Self-evident

Motor Trend 7420T0M *10011111 [79121 Last four digits in coda line

show ex data: first two

show year, last two show

month. 7912=December

1979. 

,
38

Magazine Label

Motor Cycle Sport 7920T0M *10011111 179121 Last four digits in code line

Quarterly, show ex date: first two

show year, last two show

month 7912=December

1979.

N EA Journal Label sample not furnished. Ex date not shown

National Review • XRP10000 9468 26 10211 Last three digits in code

line show ex date: first

two show month, last

shows year. 021=

February 1971.

Nation's Business Self-evident.

Edward P. Paul 1MAR71] 

Negro Digest 4112200C1-lRI 3T2234 0i07/71] Self-evid e;

New Lady magazine....... Label sample not furnished "I Oct 70 shows a oneyear sub ending Oct.

1970; 2 Oct 71. a twoyear sub ending Oct.

1971," etc. Location not

stated.

New Republic, Joe NR MMA4BB 327019 1 [:;5711 Self-evident.

New Yo.i, 2224063 0 369 16-721 Self-evident.

New Yo.er, the 313592 BRB 1949K091 150711 2 X Last five digits, ;

but two, from ;

end of code

line show

week and year

of ex date:

50•71=50th

week, 1971.

Newsw oek_ DE* 4440 MDI •J 1 0H3100 110711 Self-evident.

N„rsing,.A...‘,rican 10? 706F00091)( I71SEPI IA Self-evident.

.166ffIZ,I

t.urslng Outlook NP 340EL C90A8 [71JANI IA Self-evident.

Outdoor Life 586728 SAR B0002E93 [AUG701 0 3 Self-evident,

Outdoor World • OWWZ WST2094T93306192793213711 Last three digits

in code line

show ex date:

371=March

1971. "N indicates November-December."

Pace OKEIGE926AK 01154 [0OT731 Self-evident.

Parents 52H WRR 60 805 63 IJUL731 Self-evident.

(This ex date

style will start

"sometime in

1971.")

Perspective in Biology PA19007 ROHROHM [NOI PBM 209 15th & 16th digits in code

& Medicine, line show ex date. Examples: 13=January 1973,

59=June 1969 (7), NO

November 1970.
39

L2 Phoenix PM 008517 A 98 170121 Last four figures In code

line show year and

month of ex date: 7012=

Dec 1970.

Photo Weekly BBDNGOLD121JORSZ64.011 B9C03012..._ 20th, 21st & 22nd digits in

code line show ex date:

year (0 thru 9), week (1

thru 52).

Photoplatemakers Label sample not furnished Ex date not shown.

Bulletin.

Physiological PA19007 ROHROHM 1N01 PZ 209 15 th & 16th digits in code

line show ex date. Examples: 13 =January 1973,

59=June 1969 (7), NO=

November 1970.

Popular Electronics Label sample not furnished Ex date clearly shown two

digits in from end of

code line: i.e., "JUL70."

Popular Mechanics PM [SEP 711 10001 0 PYNICL 462898._ Self-evident.

-

,

explanitkit

Popular Photography__ Label sample not furnished Ex date clearly shown two

digits In from end of code

line: i.e., "JUL70."

Popular Sclence 336728 SAR B0002E93 [AUG 701 0 3 -Self-evident.

Presbyterian Life PMF 95627DRSIBX877M9600729 11371 Ex issue date shown in

la-St three digits of code

line i.e., 137=issue of

9/1/70.

Priect, Today's Family 01000RNCU2153792 K26B 111-701._ ..... Self-evident.

Digest, My Daily

Visitor, Our Sunday 

Visitor.

Private Pilot Label sample not furnished Example given: "John

Smith SEP"—Ex monthi

"E 70"—Ex year; may

be reversed-07.

Progreive Farmer, the 3MWZ IHECPO 4797301.19013861D721 Last three digits in code

line show ex date:

months apparently

coded 1 thru 9, Jan:

thru Sep., 0.N.D., Oct.,

Nov., Dec.

Psichology Today OMUNAA0113AB 703441DEC691AM10..... Self-evident.

Purchasing Week '56ZOCNLk54ADJA0 [JAN71] Self-evidenti

Reader's Digest, the.... B 75505 91205 PL1 IFEB721 Self-evident4

, Redbook RA25A07424ASC4MR015397R2HTV1514741.. Last three digits in code

, line show cx date:

Months cociad 1 thrJ 9,

Jan. thru Sept.; 0,N,D, ,

Oct., Nov., Dec.

Revista Notaria Label sample not furnished Ex dote not .S!".0'..1: -

Rod & Custom 7420 TOM '10011111 17912] Last four digas in code

line thaw ex dote year

'4 month: i.e., 7912= ,.- •

Dezember 1975.

Rotarian, the Label sample not furnished Ex (late not shown.

Rudder 38 89 79d0 BY3304MCJ--8 [APR741 Self-evident.

,. ,

Sales Management Label sample not furnished Ex date shown on renewal " •

notice only. ".

San Diego OMBOWR9335AN 04072[0CT721 Self-evident. ' '
40

, -*wins Label Explanation,

San Francisco' 1-2-15-701 Last three digits is code

s:.ovv ex sale:

May 158D.

Saturday Review Label sample not furnished Ex date shown clacriy as

"AP;173"—iocc,ion not

s'.f.tod

Scholastic Label sample not furnished Ex dote not shown.

School Review PA19007 ROHROH9iiN01 SR 209 15tn Z.' :6th digits in code

tine show ex date.

13=jarwary

1973, 59=June 1979

(7), NO= November 1970.

Science & Mechanics.... 15 88 0260- TEB626CAE-7 [APR731 , Self-evident _

Science Digest SDINOV721 10001 03 PRR1LT 746390_ SO-evident.

Scientific American BETLILXEM049•14711•424700CG Figures between asterisks ,

indicate ex dole: months ,

coded 1 thru 9, Jan.

th:u Oct., 0,N, D, Oct.,

Nov., Dec.

Scouting 3640075 TRNDW541C9 101)0111SA Last three numerals in

code line show ex date:

Cot thru 12=months,

o thru 9=year. I.e.,

011=Janutry 1971.

Signature 50L0-2-9269 4 [L71] Last three digits in code line

show ex date: months

coded A thru M, •

omitting I. I.E., L7I=

November 71. • • , ;,

Ski K81 F143828 11201 Last three figures in code, .•

line show ex issue. 120..

October 1974 issue.

Skiing Label sample not furnished Ex date shown clearly two

digits in from end of coda

we: i.e., "jilt_ 71."

Skin Diver 7420T0M •10011111179121 Last four digits of code line

show ex date year and ,

month. 7912= December

1979.

Social Biology PA19007 ROHROHM [NO] SB 209 15th di " digits in code

use siiaw ex date.

Examples: 13=January

1973, 59=June 1066 (7),

NO= November 1970.

Social Service Review._ PA19007 ROHROHM ENO] SS 209 15th & 16th digits in code'

line show ex date.

Examples: 13=January

1973, 59=June 1959 (7),

NO= November 1970.

Sociology, American PA19007 ROHROHM (NOISOC 209 15th & 16th digits in coda

Journal of. line show ex date.

Examples: 13=-January

1973, 59=June 1E69 (7),

NO=November 1970.

Southern Living 3MWZ IHECPD 47973011901386 [0721___ Last three digits in code

line show ex date: -

months aded 1 thru 9,

Jan. : Sep., 0, N, D,

Oct., Dec.

Spining Wheel 33470S IDEC72] Self-evident

Sportfishing J4 S 573819004 P21 A[C11 PCRA 17th 18th digits in coda

;i6.) shower

montns codad a:7'-‘a- '

bctically, last of

'car shown. CI

1971,
41

Magaz;no Label Explanation

Sports Ai;eld SA[AUG711 10001 03 PSC4VL 421590 Self-evidelq.

Sports Car Graphic 7420T0M •10011111 [79121 Last four digits of code line

show ex date year and

month. 7912 =December

1979.

Sports Lilustrated ' [MY5691 OWL PR0906192T51 42 11 First five digits in code line

show ex date, month, issue

and year. MY569 =fifth issue, May 1969.

Standard rlate & Data Label sample not furnished Ex data not shown.

(uli puPlications)

Stero Review Labe sam72e not furnished Ex date clearly shown two

digits in from end of code

line: i.e., "JUL71."

Successful Fermin,: 2 C3936005C4B-1. .506 [12741 Self-evident.

Sunset 110 468662 3 [JAN751 Self-evident.

Swimming World SCA92103RUZCC42261 ,,'112[ A 1 M 15. ...ru 22nd digits in code

s.sow year and month of

ex date: 7112—December

1971.

TV Guide 12th, 13th & 14th digits in

81702201 823 [977161 code line show ex issue,

which appears on masthead. Ex date not shown.

TV Raci:s Talk DS LBL4MNI29E009 01 [07741 Self-evident.

Tan X3841C0THM155385683 [09/711 2_ Self-evio,

Technology & Culture... PA19007 ROHROHM[NO1 TC 209 15th & 16th digits in code

line show ex date. Ex...1-

ples: 13=January 1573,

59=June 1969 (7), NO=

November 1970.

Teen 7420T0M '10011111 179121 Last four digits in code line

show ex date year and

month. 7912=December

1979.

T.rne [AU71] TIE AE224M94T56 84 67 Self-evident.

Today's Lucation f.abel sample not furnished Ex date not shown.

Tocay's Health Tri JSS38X132V055 03 [0871] Self-evident.

Top OP CO 6C9250 WEE*KN 0 [70081 Last four digits in code line

show ex date: year

followed by month.

7008 =August 1970.

T,,,.n & Coui.try. T0[DEC711 10001 03 PRZ2CR 451291.... Self-evident.
42

Magazine Label Explanation

Travel • MX011-31-711-66-000124CG Ex date shown as marl..

at left, No explanation

given.

True 88 89 7980 BYR304MCJ--8[APR74] . Self-evident.

U.S. News & World 63HDA94025LNZ2ST009692UX210EC711.. Self-evident.

Report.

Vend BBDNGOLD121JORSZ64010111B9G03612.. 20th, 21st & 22nd dig,i;s in

code line show ex ti,:e4

Year (0 thru month

(1 thru 12). 0:1=

November 1:70.

Venture AES4 1070 265127 VE 103711 Self-evident

Vogue 321100 KNI 0019G093 [SE1751 1 7 Last Zve (or fov)

except two, ';ram ad

code line thaw ex date,

month, day and year.

S.i175=Seo. i 1, 1975,

SE275—Se7. it. :575.

;,;anths when only ono

issue published shown

without numeral between

month and year: i.e.,

71.

Washingtonian ,. ,-330HASK F241 *69199 21221. Last two (or three) ds

of code line show ex

date: i.e., 22= February

1972.

Western Outdoors WCA:.7'7,16MOSLE34311 17301115 Last four digits, save two,

in code line show ex

date, year and month.

7301—January 1973.

Wheels Afield 7420T0M *10011111 179121 Last four dits in code

line show ex date, year

and month. 7912=

• December 79., '

Yachting 073.3574R [1270] 0021L912N Self-evident.

Yankee XC10100639 KINSEDB#ZHL Self-evident

112/711 

Young Miss 3213 1 ZGR 10 0.11260,01741 Last two figures in coda

;ine show ex issue number. (Sometime in 1971

will be changed cleat

showing of "OCT 71,"

etc.)

Ziff-Davis (all publi- Self-evident

cations). NAY 741 

Zygon PA19007 ROHROHM1NO] ZY 209.......... 15th & 16th digits in code

line showex date.

Examples: 13—January

1973, 59—June 1969 (7),

.NO= November 1970.
43

qdedl

e6ee/ite4m4 eaterP

f000 e.,4.oues24naer

g. e27

2o2 2,96-,167,90

March 10, 1972

Hon. Robert N. C. Nix

Chairman, Subcommittee on Postal

Facilities and Mail

Room B345B

Rayburn House Office Building

Washington, D.C.

Attn: Mr. Tom Kennedy

Dear Congressman Nix:

We are counsel for the Classroom Periodical Publishers

Association whose members mail classroom and Sunday School

publications to school children throughout the United States.

These valuable teaching aids are designed specifically for use

in classrooms or in religious instruction classes.

We note the introduction of H.R.8659 by Rep. Dulski

and the hearings held by your Subcommittee on Feb. 24, 1972.

It would appear that the legislation is useful

particularly where it applies to magazine subscriptions of

varying length. The average person is not able to translate

and read the coding on the address label which informs one

of the expiration date.

However, insofar as classroom publications (which

include religious instruction publications) are concerned

(as defined in Section 4358(j) of Title 39, U.S.Code), it

would appear unnecessary to have the protection of H.R.8659.

Our school publications are sold for a specified time period,

that is, a school year or a school semester. Thus, the addition of an expiration date on the label could be troublesome

and difficult. Also, the publications are usually sent to the

teacher in bulk and she distributes the copies to students in

the class. This is convenient for the teacher and also saves

postal expense.
44

H.R.8659 could be interpreted to require that each

copy in the bulk package addressed to the teacher be

individually marked with each student's name if the student

were a "subscriber." This would appear unnecessary and

burdensome from an expense standpoint.

Also, certain of our members who publish religious

instruction publications,in certain appropriate situations

use what is known as "TF" subscriptions, "TF" meaning until

forbidden. This is a subscription that has no termination date

but continues until the subscriber cancels.

Certain of our members, publishing religious instruction materials, mail one quarter's material at a time and are

paid therefor. This is really the same as buying a one month

copy of a magazine and paying for it with no further obligation.

It is not really a subscription. H.R.8659 could present problems in this area too.

In summary, what seemed to be a simple and concise

piece of legislation, namely H.R.8659, generates all sorts of

problems for the members of our association, as you can see

from the above points.

Therefore, we would appreciate it if your would give

consideration to an amendment of H.R.8659 as follows:

page 2, line 1 

Add the following after the word "publication"

and before the word "having":

, except classroom publications, --

If you have any questions on this, we would be

pleased to answer them. Thank you for your kind consideration

of our views.

Sincerely,

COUNIHAN, CASEY & LOOMIS

Stephen F. Owen, Jr.
45

92D CONGRESS

1ST SESSION °ti‘ v. R. 8659

IN THE HOUSE OF REPRESENTATIVES

MAY 24, 1971

Mr. DuLsiu introduced the following bill; which was referred to the Committee on Post Office and Civil Service

A BILL

To amend title 39, United States Code, as enacted by the Postal

Reorganization Act, to require that the mail label or other

cover of any publication having periodical publication mail

privileges, when mailed to a subscriber, shall bear readily

intelligible information regarding the name and address of the

subscriber and the expiration date of the current subscription,

and for other purposes.

1 Be it enacted by the Senate and House of Representa2 tives of the United States of America in Congress assembled,

3 That section 3685 of title 39, United States Code, as enacted

4 by the Postal Reorganization Act (84 Stat. 765; Public Law

5 91-375) , is amended by striking out subsection (c) thereof

6 and inserting in lieu of such subsection (c) the following:
46

1 "(c) Each publication having periodical publication

2 mail privileges, when mailed to as subscriber, shall be

3 mailed with or under a mail label or other mail cover which

4 bears the following information in a form readily intelligible

5 to the reader:

6 "(1) the full name of the subscriber;

7 "(2) the complete mailing address of the subscriber,

8 including any code or other method maintained by the

9 Postal Service to expedite the transmission of mail

10 matter; and

11 "(3) the date of expiration of the current sub12 scription.

13 "(d) The Postal Service shall make appropriate rules

14 and regulations to carry out the purposes of this section, in15 eluding provision for suspension or revocation of periodical

16 publication mail privileges for failure to furnish the required

17 information or to comply with the requirements of subsection

18 (c) of this seetion.".

19 SEC. 2. The amendment made by this Act shall become

20 effective on the ninetieth day after the date of enactment of

21 this Act.
47

EXECUTIVE OFFICE OF THE PRESIDENT,

OFFICE OF MANAGEMENT AND BUDGET,

Washington, D.C., November 8, 1971.

Hon. THADDEUS J. DULSKI,

Chairman, Committee on Post Office and Civil Service, House of Representatives, Washington, D.C.

DEAR MR. CHAIRMAN: This is in reply to your request for the views of the Office

of Management and Budget on H.R. 8659, a bill "To amend title 39, United

States Code, as enacted by the Postal Reorganization Act, to require that the mail

label or other cover of any publication have periodical publication mail privileges, when mailed to a subscriber, shall bear readily intelligible information regarding the name and address of the subscriber and the expiration date of the

current subscriber, and for other purposes."

For the reasons stated by the Postal Service in their annual report to you on

this bill, the Office of Management and Budget recommends against enactment of

H.R. 8659.

Sincerely,

WILFRED H. ROMMEL,

Assistant Director for Legislative Reference.

U.S. POSTAL SERVICE,

LAW DEPARTMENT,

Washington, D.C., November 10, 1971.

Hon. THADDEUS J. DULSKI,

Chairman, Committee on Post Office and Civil Service, U.S. House of Representatives, Washington, D.C.

DEAR MR. CHAIRMAN: This is in response to your request for a report OD

H.R. 8659.

This measure would add a new subsection (c) to section 3685 of title 39, United

States Code, providing that each periodical publication shall be mailed to a subscriber with a mail label bearing the following readily intelligible information:

(1) the full name of the subscriber;

(2) the complete mailing address, including any code, or other method

maintained by the Postal Service to expedite transmission of mail matter;

and

(3) the expiration date of the current subscription.

Existing subsection (c) would be renumbered as subsection (d) and would be

amended to authorize the Postal Service to enforce the new subsection (c).

The Postal Service is opposed to the enactment of H.R. 8659. Under the

Postal Reorganization Act, the Postal Service has been charged by Congress

with the duty to "plan, develop, promote, and provide adequate and efficient

postal services at fair and reasonable rates and fees." 39 U.S.C. § 403(a). The

determination of what information should be included on address labels, which

the bill proposed to legislate, is a matter of operational policy to be appropriately

in our opinion, determined by Postal Service management in discharge of its

general duty to provide adequate and efficient postal services. We believe that

amendments to the Postal Reorganization Act to legislate matters affecting dayto-day postal operations are unnecessary and could prove harmful.

As to the bill's requirement that the full name of the subscriber be placed on

the label, our current regulations do not forbid the common practice of abbreviating first names, since we have not found the full name to be necessary for

proper delivery of the mail. Moreover, we understand that the reason for such

abbreviations is basically one of the added cost to publishers of carrying the full

name in their computer-accessible records. Accordingly, it is our opinion that

including the full name may be an unnecessary economic burden, and we would,

therefore, not be inclined to require it at this time unless significant countervailing benefits accrued to subscribers. However, the Postal Service has the authority to require this information if it becomes desirable to do so, and consequently

legislation is not necessary to provide for it.

While Postal Service regulations do not require inclusion of the expiration

date on the mailing label, they do permit, as additions to the envelopes or

wrappers of periodical publications, "written or printed words or figures, or
48

both, indicating the date on which the subscription will end." 39 C.F.R. § 132.4

(g) (2) (v). We know that many publishers voluntarily include this information in some form on the label. Although this kind of information may be helpful

to subscribers, it does not aid the Postal Service in delivering the mail. Indeed,

the addition of words and numbers, in too-close proximity to the address might

interfere with the use of address reading machinery which the Postal Service

hopes to develop and use in the future. If mail delivery should be impeded for

this reason, some amendment of the above regulation would be in order. Therefore, we believe it is unnecessary and could prove harmful to require by statute

information of this nature.

As outlined above, the Postal Service believes enactment of H.R. 8659 is unnecessary and could prevent the achievement of improved mail service, by freezing in statutory form requirements which should be imposed, if at all, through

the more flexible regulatory approach presently available to the Postal Service.

Accordingly, we oppose the proposed legislation.

Sincerely,

DAVID A. NELSON,

By: Louis A. Cox,

Solicitor.