In “Postmarks and Postal Possession,” a proposed rule published in the August 12 Federal Register, the Postal Service sought to establish a distinction between the date shown on a postmark and when the USPS was actually in possession of a mailpiece.
After a lengthy exposition about the history of postmarks and how the Postal Service has applied them, the crux of the proposal was presented:
“… the Postal Service is using this rulemaking as an opportunity to educate the public about the information that postmarks convey and the methods customers can use to confirm that the Postal Service had possession of a mailpiece and the date on which such possession occurred. …
“The postmark is not currently defined in any Postal Service regulation. The proposed DMM language will clearly define the postmark (including the significance of the date appearing on a postmark); will identify the various markings and indicia that qualify as postmarks, together with the locations at which such postmarks are applied; and will explain the information that such postmarks convey, specifically regarding the date when the Postal Service accepted possession of a mailpiece. It will then remind customers who wish to retain proof of the date on which the Postal Service first accepted possession of their mailpiece(s) of the services (including Certificates of Mailing) that provide such proof. Finally, it will identify certain auxiliary markings and scan data generated during the course of postal operations which indicate postal possession of a mailpiece (but not necessarily the date on which the Postal Service first accepted possession of a mailpiece). To be clear, and as noted above, this provision simply reflects in the DMM the Postal Service’s current operational practices regarding postmarking, and makes no changes in that regard.”
The USPS clearly intends to remove any public belief that the point at which the agency came into possession of a mailpiece correlates to the postmark:
“The presence of a postmark on a mailpiece confirms that the Postal Service had possession of that mailpiece on that date (i.e., that the item was in the mailstream on the identified date). However, the postmark date does not necessarily indicate the first day that the Postal Service had possession of the mailpiece. Moreover, the absence of a postmark does not suggest that the Postal Service did not have possession of the mailpiece.”
Moreover, many types of mail are not postmarked, the USPS noted, including pieces with a permit imprint indicia, precanceled stamp, or meter impression, though a postage statement can show both USPS possession and the date of mailing. Regardless, the USPS noted the situation in which the disconnect between postmark and possession will become more important to senders:
“The RTO initiative will make the scenario where a postmark date does not align with the date that the Postal Service first accepted possession of a mailpiece more common. … In ZIP Codes where at least one delivery unit is located beyond a 50-mile driving distance threshold of its servicing RPDC, RTO consolidates drop-offs of destinating mail and collections of originating mail on a single transportation route … .
“… As a result, pick-ups of originating volume subject to RTO’s consolidated transportation scheme will generally occur the day after such volume is tendered to the Postal Service by a customer. Thus, RTO-impacted volume that first enters postal possession on a weekday not immediately followed by a holiday will be transported to a facility to be processed (and, as appropriate, postmarked on our automated cancellation machines) the following day. With the elimination of Sundays and holidays as transit days for the purposes of service performance measurement, RTO-impacted volume that first enters postal possession on a Saturday may be processed (and, as appropriate, postmarked by the automated machinery) the following Monday – a gap of two days; similarly, RTO-impacted volume that first enters postal possession on a weekday immediately before a holiday will generally be processed (and, as appropriate, postmarked by the automated machinery) on the day after the holiday – also a gap of two days. Finally, RTO-impacted volume that first enters postal possession on a Saturday preceding a Monday-holiday may be processed (and as appropriate, postmarked by the automated machinery) on Tuesday – a gap of three days.”
The proposal notes that customers who want evidence of when a mailpiece was tendered to the USPS can use Certificate of Mailing, Registered Mail, or Certified Mail – and pay the applicable fee. (The proposed rule incorrectly cites the corresponding sections of the Domestic Mail Manual as 500.5, 500.2, and 500.3, rather than 503.5, 503.2, and 503.3, respectively.) Defining the postmark and explaining its relevance as an indicator of postal possession may seem innocuous, or even unnecessary for those who understand postage payment and cancellation practices. However, linking the proposal to RTO may explain the real purpose – to satisfy the legal requirement for public notice – but doing so also publicizes (albeit not very widely) the service impact that will be imposed on post offices and their customers as RTO is implemented.