Notice & Comment

USPS Seeks Input on Proposal to Simplify Return Services, by Shannon Allen

The United States Postal Service (“USPS”), issued a Rule document, inviting public comment on a proposed interim rule to simplify return services.  The USPS proposes to reduce “customer confusion” and guarantee dependable administration by adjusting the “total annual volume thresholds” that USPS Return Services products have to meet in order to “qualify for Commercial Plus® pricing.”  Specifically, the proposal establishes a “minimum volume of 50,000” pieces of mailfor Return Service “across the board” which will simplify the product and make it less confusing for “customers to do business with the Postal Service.”

At this time, “Commercial Plus® pricing” for products under the “USPS Return Services umbrella” require “different annual volume thresholds.”  These products are: Priority Mail® Return Service, First-Class TM Package Return® Service, and Ground Return Service.  Because of the confusion surrounding different products with different volume threshold requirements, the USPS has determined that it is immediately necessary to simplify its returns shipping options.

Current requirements are as follows: 

  • Commercial Plus pricing is available for cumulative Priority Mail Return Service and First-Class Package Return Service volume exceeding a combined total of 25,000 return pieces in the previous calendar year.  
  • Commercial Plus cubic volume must exceed a combined total of 85,000 pieces returned in approved packaging in the previous calendar year, or cumulative returns and outbound volume must exceed a combined total of 90,000 pieces in the previous calendar year to qualify. 
  • Commercial Plus pricing customer commitments may differ depending on the individual signed agreements with USPS.

The USPS has learned that these varied and overlapping requirements are unclear to customers and make it challenging to do business with the Postal Service.  Not only does this proposed interim rule help make it easier for customers to do business with the Postal Service by providing better clarity of criteria, but also it better aligns with “recently adopted changes to the Priority Mail cubic threshold, and to the outbound Priority Mail CPP threshold, of 50,000 pieces.”

This proposed interim rule seeks to provide consistency for customers without signed agreements by creating a “minimum total annual threshold volume requirement of 50,000” for all USPS Return Service products “in order to qualify for Commercial Plus pricing.”  This new approach would not impact customers with the “25,000 piece threshold until their agreements expire.”  At which time, the “50,000 piece threshold” would become applicable“unless an extension is requested and approved by the Vice President, Sales.”

This proposed interim rule is effective September 15, 2014.  The USPS invites interested parties to submit comments on or before November 10, 2014 by one of the following methods: 

  • Mail or deliver written comments: To the manager, Product Classification, U.S. Postal Service, 475 L’Enfant Plaza SW., Room 4446, Washington, DC 20260-5015; You may inspect and photocopy all written comments at the USPS® Headquarters Library, 475 L’Enfant Plaza SW., 11th Floor N, Washington, DC, by appointment only between the hours of 9 a.m. and 4 p.m., Monday through Friday, by calling 202-268-2906 in advance.
  • Email comments: Email must contain the name and address of the commenter and may be sent to:, with a subject line of “Threshold Volume for USPS Return Services.” 
  • Fax:  Faxed comments are not accepted.

This post was originally published on the legacy ABA Section of Administrative Law and Regulatory Practice Notice and Comment blog, which merged with the Yale Journal on Regulation Notice and Comment blog in 2015.

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