(of course I'd show up for this...)
From one of the many threads on this topic...
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gifflefunk (1012) (view author's auctions)
05/12/04 10:39 PM(#69 of 88)
Ok... I couldn't sleep so I went off to pe.usps.gov and I found the actual postal regulations.
The two areas that relate to our discussion here are the following sub-sections E610 Basic Standards (in the E600 Standard Mail section) and E713 Media Mail (in the E700 Package Services section).
E610 2.2 Printed Matter
Printed matter weighing less than 16 ounces may be sent as Standard Mail. For this standard, printed matter means paper on which words, letters, characters, figures, or images (or any combination of them), not having the character of a bill or statement of account or of actual and personal correspondence, are reproduced by any process other than handwriting or typewriting.
Ok, no mention of advertising here... just bills, statements of account and correspondence. So comic books are printed matter.
E713 1.1 Qualified Items
a. Books, including books issued to supplement other books of at least eight printed pages, consisting wholly of reading matter or scholarly bibliography, or reading matter with incidental blank spaces for notations and containing no advertising matter other than incidental announcements of books. Advertising includes paid advertising and the publishers' own advertising in display, classified, or editorial style.
c. Printed music, whether in bound or sheet form.
[b,d-i items deleted as they are irrelevant to the discussion]
Ok, this would exclude comics that contain paid advertisments that exist as pages. I'm not sure about the obsolete aspect for advertisments published in the 1950s, but for arguments sake we will call all paid advertising (be it current or obsolete) as advertising. So comics do not qualify as Media Mail.
E713 1.2 Loose Enclosures
In addition to the enclosures and additions listed in E610, any printed matter that is mailable as Standard Mail may be included loose with any qualifying material mailed at the Media Mail rates.
Look, a loophole! You can print out a sheet of music and include it in a package containing no more than 16 ounces of comic books and the package can be shipped as Media Mail. The sheet of music is qualified material and comics meet the definition for Standard Mail. So long as you are only sending 1 pound or less of comics, with the sheet of music, it can all go Media Mail!
Now, there is still that question regarding obsolete advertising still being advertising vs. historical text (the argument being "how can you advertise something that no longer exists?"). Has it become historical text and hence part of the reading material? If so, older comics may qualify under E713 1.1 a as Media Mail. I plan to take this post into my local Main Office to get a definition on "advertising vs. historical text".
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gifflefunk (1012) (view author's auctions)
05/14/04 08:28 AM(#81 of 88)
Ok folks, I just got off the phone with the head of Media Mail at Rates and Classifications in Chicago, IL.
Here is his take on the situation... as E713 1.1 a says "advertising" and makes no provision for obsolete advertisments vs. current advertisments, he says that any postal branch is operating within the regulations to refuse comic books that contain any advertising.
Now he wasn't aware of the RIBBS precedent set for reprinted historical catalogs being allowed under Media Mail (PS-064 in the RIBBS system). But he understands the logical argument (by extension) that if a product is no longer being produced, or the vendor is no longer in existence, that no one can benefit from the advertisment and so it has become historical in nature and has become part of the reading text. The problem he sees is in verifying that all of the products are unavailable and that the vendors are out of business (and trying to determine such a thing could get messy and take more time than it is worth).
Now I explained to him that some people were getting comic books rejected, and others were not, based on their local POs interpretation of the Media Mail rules. He said the only way for us to get a National rule would be through a "hearing" on this issue. And it would work this way... someone who gets comic books rejected at their local office would need to appeal that ruling locally and get it worked up the ladder to Rates and Classifications in Chicago. This appeal is where we can present our our "case" as to why vintage comics should be allowed to qualify for Media Mail. Once it gets to him then he would investigate the matter, taking our position as part of that investigation, and then make a National ruling.
So we would need a damn good set of reasons to allow comic books otherwise we risk losing Media Mail privliges for all dealers that are currently allowed to send comics under that rate by their local POs. He said sometimes it is better to leave it alone.
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My local PO told me that they classify any advertising more than 3 years old as obsolete, so any magazine (comic books, TV guides, etc.) are eligible for Media Mail if they are that old or older.