Frustrations in International Mail

This article was produced by Merry Law, Mailers Hub’s expert consultant on international mail. Merry may be reached at [email protected].

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I recently wrote two articles for this newsletter on what’s happening in the international mail arena at the Universal Postal Union and at the USPS. While I try to present facts and developments in a neutral way, those reading between the lines might conclude correctly I am not optimistic about the immediate future for the international mail environment.

Here is my opinion: unless there is progress at the UPU for the international network and at the USPS for our own inbound and outbound mail, we face a spiral of deteriorating international postal service, affecting US mailers, e-retailers, and consumers.

The Postal Service

For the USPS, international mail generates more than twice the revenue of Periodicals with less than one-fifth the volume of pieces (I do understand there are important current and historical reasons for emphasis on Periodicals) but international revenue is only 3.3% of the USPS’s total in FY 2021.

So, international mail receives comparatively little attention from the USPS, with responsibilities split between three different functional units, with another handling international relations. Many of the USPS staff, including senior management in these units, do not have a great deal of experience or familiarity with international business, although some are experienced in this area.

USPS is working on its own “Duty and Delivery Paid” solution for outbound goods mailed to other countries. Usually termed Duty Delivery Paid or DDP, this would allow the sender to pay the duty, an advantage for B2C companies that has long been available from non-postal carriers.

USPS did not subscribe to the International Post Corporation (IPC) DDP solution, made available to postal operators for a fee. USPS is apparently working to get its own tested and available as soon as possible. Nothing has been announced publicly or at MTAC or any other forum as far as I can determine. Input by and testing with mailers and mail service providers would generate ideas and feedback for a successful solution. Hopefully, it will work better than the dysfunctional online customs form, which hasn’t worked consistently for more than two years.

The UPU

At the same time, the UPU is moving very slowly on a number of things — including administrative reform and rule-making for Advance Electronic Data – creating annoyance, impatience, irritation, and frustration among UPU representatives, postal operators, and other interested parties.

Meeting are on a fixed schedule (often quarterly) and submissions must be made well in advance with some requirements for pre-clearance by a body of “experts.” The expert panels are appointed by their countries from their postal operators or their government. Expertise may take a back seat to political or parochial interests.

The US representative at the UPU was changed by the US Congress in 1998 from the USPS to the Department of State, but USPS staff provide expertise and represent the US in some UPU committees and working groups.

Some USPS staff are seen as slow-walking some of the needed items to create new and updated standards at the UPU. Changes to standards are needed to implement consistent and comprehensive regulations for AED, required by the US, the EU, and other countries for the safety and security of imports.

The perception among some here and abroad is that USPS staff’s prime goal is preserving the postal operators’ prerogatives and protections, creating the bare minimum for postal AED to meet the requirements of the US and EU countries, and opposing anything that’s not to the USPS’s advantage, even if it’s neutral. Whether this is a fair assessment or not, it undermines the perception and the reputation of the US.

Data

Currently, postal operators are not legally responsible for the accuracy of the customs information or the contents of packages and can’t be fined or prosecuted by other countries, unlike private delivery services and carriers.

For inbound postal matter, this has presented a conundrum for Customs and Border Protection (CBP) and USPS. Senators are again annoyed about the lack of compliance with the STOP Act. Read more HERE, in this article, or a recent expression of concern.)

The USPS has consistently objected to stronger actions against foreign postal operators, citing ambiguous language in the UPU Acts. Is there potential for foreign action against USPS? Definitely, but how much and how should that weigh against the US inbound potential harm?

There is tension between CPB and USPS on STOP Act enforcement, based on occasional comments those in the international space have heard. (There are also unanswered questions about how and how much AED is used by CBP, with some estimates as low as 1%-5%.)

Reform

UPU reform is again on the table. The UPU opening its membership to a broader group has been an on-and-off discussion.

Governmental and operational functions at the UPU are not separated. That was fine when posts were governmental agencies, but, in most developed countries and some developing countries, posts are no longer exclusively government-owned and competition is allowed. Because of this, separating the governmental and operational functions of the UPU is important.

The issue is becoming more imperative but is very divisive. After more than five years of discussions, a task force is being formed, with the US as one co-chair. The meeting creating the task force became so antagonistic that Kenya withdrew its nomination as co-chair.

Overall, this is the tensest time I’ve seen in both the UPU and in the USPS international area. That hostility between the USPS staff and the industry participants was lower at the January MTAC meeting was positive, but that’s a meager step given their divergence of opinion on a host of issues.

I am not optimistic about the future of the USPS or the UPU. Without reform, the UPU will become increasingly irrelevant. I’m sure you have your own thoughts on USPS’s future.

We all need to step up. We are all part of this larger economic sector. Engaging with USPS, through MTAC or through other public meetings or any other contacts with USPS, should encourage non-hostile dialogue. We, the public, can make our opinions on opening the UPU known to the State Department through the Advisory Committee on International Postal and Delivery Services.

Ratepayers and commercial mail producers need to make their needs and opinions known. Here are some ways to start:https://www.apa.org/advocacy/guide/letter-email  How to write your US Representatives and Senators who are considering legislation on postal reform and providing additional funds to USPS. (From the American Psychological Association, it’s the most complete I have seen and good advice for writing to influence other governmental groups.)https://www.prc.gov/contact  Send comments to the Postal Regulatory Commission (PRC) on “how the Commission can do a better job.”And let Mailers Hub and other groups you belong to know your opinions as well.