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Written comments - Merry Law


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There are two issues that will be raised in committees in Bern that I would like to bring to your attention. I also have an additional comment.

1) Members of the UPU Consultative Committee are exploring how and in what committee to best raise the issue of labels placed by postal operators on returned items. In some significant proportion of the returns, the label obscures the undeliverable or incorrect address. This is perhaps done to prevent "looping", where the undeliverable item is returned to a post center, goes back into processing as a deliverable item, is returned again as undeliverable, and so on. The labels are often permanent and cannot be removed. For business mailers, a permanent label completely obscuring the address makes it difficult, and sometimes impossible, to eliminate the address from future mailings or to attempt to correct the address. For a mailer, this is likely to create another loop, where the company mails to a client or prospect over and over, never learning that the item is undeliverable. In short, receiving back unobscured copies of addresses of undeliverable mail is critical for mailers to maintain their own interest in continuing to use the medium.

The basic initiative will be to ask for a rule in the postal regulations to require removable labels or that the label does not obscure the address or both. I do not know if this requires any discussion by the IPODS committee. Indeed, it seems clear to me that there should be support for this initiative, since international returns are costly for the postal operators and this would potentially decrease the volume of undeliverable returns. This issue is not contained in the material sent by you or Charles Prescott in preparation for the March meeting but is likely to be raised at the UPU committee meetings in April.

2) The ongoing work on UPU standards S42 International postal address components and templates and S53 Exchange of name and address data will be discussed by both the Standards Board and the Addressing Group. I would urge the U.S. to support the continuing work and back the recommendations of the IB staff in regard to these standards. I strongly support making S53 a part of S42 rather than remaining a separate standard. (I am a member of the UPU's Address Templates Working Group. The opinions I express here are influenced by that work, of course, but are my own.)

There has been significant progress on S42 in the past few years and the work is at a critical point. Discussions and preparations are well underway for S42 to be accepted as an ISO draft standard, which will result in the recognition of a single addressing standard by the world's major standards organizations. The S42 standard is descriptive and its adoption by ISO retains the primacy of the UPU in the addressing standard and each individual country as the authority for approval of its own address template.

3) U.S. representation at meetings of UPU committees and groups is very important both to the U.S. and the international community. A lowered presence of the U.S. has been raised in more than one context recently that have come to my attention. Without more details, I cannot say whether this is real or perceived. In any case, I would like to state my view that a U.S. presence is important at UPU meetings, including in committees and groups.



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