Improper....in violation of USPS Rules and Regulations, a Federal Entity.
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The governing document of the USPS is the Domestic Mail Manual. According to the DMM, comics aren't excluded. Advertising is excluded. Expired advertising is no longer advertising; it is reference material.
If I can't buy 7 giant dinosaurs for $1.00 from "Dept B3511" in NY, then there's nothing being advertised, and it's no longer an ad.
And the point and spirit of the restriction is clear: "Periodicals" is a special class of mail, with its own rates and programs. Here's the definition:
"The Periodicals class of mail is designed for newspapers, magazines, and other periodical publications whose primary purpose is transmitting information to an established list of subscribers or requesters. Periodicals must be published at regular intervals, at least four times a year from a known office of publication, and be formed of printed sheets. There are specific standards for circulation, record keeping, and advertising limits."
That function was fulfilled when the books were originally sent out to subscribers...that is, new comics, created and sent by the publisher of that material.
And since periodicals are (generally) paid for with advertising, that's part of the reason why they have their own separate category.
But people who ship back issues, one to another, are not fulfilling the role of the publisher, and sending out "periodicals" (that is, appearing on a regular interval) to "subscribers or requesters."
They have become second-hand, used material...and that's precisely what used to be 4th class, then book rate, now Media Mail, was made for.
"But, some of those ads are still valid!" Fine, some of them are. But the vast majority are not, and weren't intended to last indefinitely. And if the ad is expired, and is no longer advertising anything (even for products that may still exist), it's no longer an ad...it's reference material.
Yes, I'm well aware that someone at the USPS put a "comics are excluded" note on the website.
The website doesn't determine the regulations and procedures of the USPS. The DMM does. And if it's not in the DMM, it has no regulatory weight.
If gov't can work AGAINST us, gov't can certainly be made to work FOR us.