USPS Plans To Discontinue Dual Labels For Private Shippers, Saying They No Longer Serve Postal Service Interests
UPDATE 12-13-24
The proposed rule to discontinue Dual Labels has been approved and will go into effect January 1, 2025.
A notice posted to the Federal Register includes comments that were submitted as part of the approval process, with some requesting an extension of time and others expressing concerns this solution does not account for specific use cases or the definitions in the new rule are unclear.
Comment:
Three comments requested an extension to the effective date.Response:
The Postal Service has taken these comments into consideration and, upon request, may provide a 90-day extension for compliance until April 1, 2025, for mailers specifically impacted by the elimination of dual shipping labels.However, the effective date will remain January 1, 2025. Mailers seeking an extension should submit a request to the attention of Nicole T. Wilson at
delivery.confirmation@usps.gov.Comment:
One comment suggested the proposed solution failed to account for specific use cases where there is no clear alternative to dual shipping labels.Response:
The Postal Service has considered specific use cases and determined that there are few, if any, instances in which there are no alternatives to dual shipping labels. The shipper always has the option to simply determine in advance of label creation what carrier will ultimately deliver the package.Alternatively, if a dual label was created after the effective date of the rule, such label could simply be over labeled or the carrier markings could be obliterated in such fashion as to only display the selected delivery carrier's markings.
Comment:
One comment suggests that the definition of what constitutes a “dual shipping label” for purposes of the enforcement of this rule is unclear.Response:
The Postal Service has considered this comment. DMM section 602.10.0 currently states, “Dual shipping labels are used by private shipper[s] to identify both the Postal Service and a private carrier as possible delivery agents.” This definition will now be reinserted into the new rule.Consistent with this, under the new rule, a label that identifies the Postal Service as the carrier may also include additional items of information so long as none of those additional items of information identify delivery agents other than the Postal Service.
In other words, a label will not be considered a prohibited “dual shipping label” simply because it includes additional information beyond what is required for Postal Service label and address formats.
Instead, it will only be considered a dual shipping label if any of the additional information included thereon identifies or can be used to designate delivery agents other than the Postal Service.
While those comments were taken under advisement and responded to, they will not change the outcome of the ruling and the plan to discontinue Dual Labels will move ahead on January 1, 2025, with some possible exceptions for those who request and are granted a 90 day extension.
Once the new rule is in effect, items bearing dual shipping labels should not be accepted and may be returned to the sender.
USPS has proposed a new rule that would amend the Domestic Mail Manual to discontinue the use of dual shipping labels by industry shipping partners as Delivering For America plan looks to move away from policies and services that "no longer serve the interests of the Postal Service."
Dual shipping labels are used by private shippers to identify both the Postal Service and a private carrier like UPS, Fedex, or DHL as possible delivery agents and are most often used for services where USPS may handle the last mile of delivery such as UPS SurePost, FedEx Ground Economy (formerly SmartPost) or DHL Ecommerce.
The rule change proposal was published to the Federal Register today and will be open for public comment until November 14, 2024.
Background
On January 21, 2018, the Postal Service revised the DMM to provide information regarding the use of dual shipping labels based on feedback that some of our industry shipping partners had adopted the practice of using shipping labels which included both the USPS® and their own address formats to address their items.
Proposal
The Postal Service has reviewed the practice of using dual shipping labels and has found that this practice no longer serves the interests of the Postal Service. As a result, the Postal Service is proposing to discontinue the use of dual shipping labels. Items bearing dual shipping labels should not be accepted and may be returned to the sender.
The Postal Service is proposing to implement this change effective January 1, 2025.
That previous postal bulletin from 2018 had to sought to address confusion about which carrier performed the final delivery for packages with dual labels.
United States Postal Service
Effective January 21, 2018, the Postal Service™ will revise Mailing Standards of the United States Postal Service, Domestic Mail Manual (DMM®), part 602, to add a new section regarding the use of dual shipping labels.
Some of our industry shipping partners have adopted the use of dual shipping labels, which include both the USPS® address format and their own address format for addressing items.
The use of dual shipping labels allows private shippers to decide, after they have accepted items for processing, whether they will fulfill the delivery themselves or provide the items to the Postal Service for delivery.
Because these shipping labels do not clearly indicate who made the delivery, the Postal Service has received feedback from customers (who are unable to determine which shipper delivered their items) for items that were never in possession of the Postal Service.
To eliminate this confusion, items bearing dual shipping labels that are not tendered to the Postal Service for delivery must clearly indicate the private shipper responsible for delivering the item on the label.
The changes come as USPS announced last month it is ending discounts for shipping consolidators in effort to slow USPS losses.
Consolidators account for about a quarter of total USPS parcel volume, moving ~2 billion packages through the Postal Service each year but Postmaster General Louis DeJoy is looking for ways to boost postal revenues and efficiencies while encouraging shippers to use services offered directly by USPS such as Ground Advantage instead of consolidator services.
Liz Morton
The writing signalling a shift in volumes has been on the wall for months with several carriers keeping more of the packages they had previously shuffled to USPS in their own delivery networks for final mile delivery - for example FedEx rebranded their SmartPost service to Ground Economy as they have moved away from using USPS for those deliveries and UPS has moved more SurePost volume to fully in their network as well.
USPS also put out announcements in July advising shippers that would no longer be allowed to drop off FedEx Ground Economy, UPS SurePost or other hybrid services packages at USPS facilities.
Dual labels may be confusing, especially to consumer shippers or smaller online sellers who purchase labels through marketplaces who might still try to take those packages to USPS.
If USPS is still seeing people trying to use them for drop off, they may have taken this action to try to relieve themselves of that headache by removing what they think could be causing the confusion from the label process.
While the proposed dual label discontinuation has not yet been approved, it would appear some label providers or carriers may already be making changes to how labels and tracking for these hybrid services work.
An eBay seller who purchases labels from a third party (not eBay) says they recently noticed UPS SurePost labels no longer included any USPS information either on the label or when looking at the tracking record.
robbie31415
Yesterday and today my SurePost labels seem to go directly to buyer..There is no USPS information on the label. It's blank. Am I tripping ?
Even the online tracking doesn't reference the USPS tracking anymore.
Idk i was like. Uh where is the USPS information. These are third party labels.
Some speculated it could be related to the announcement of discounts being discontinued for consolidators and that UPS may simply be handling the delivery themselves for more and more SurePost packages.
If I had to guess I'd say it's due to the recent announcement of USPS ending discounts to consolidators like UPS and DHL that use USPS for last mile delivery.
Without those discounts, UPS is probably handling the service end-to-end now. Which they were already doing for some locations anyway.
USPS has made it clear they are no longer interested in handling last mile delivery for other carriers if it doesn't fit in revenue raising plans, as Dejoy has directly said it is not in the best interest of the Postal Service and his focus is on increasing usage of USPS Ground Advantage service instead.
“It’s challenging for us to justify entering into NSAs that incentivize bypassing our transportation and processing network, while leaving us responsible for managing the final mile, which is often the most resource-intensive part of the delivery process. To continue this practice is not consistent with our business strategy to create an efficient network and grow our own end-to-end ground package product (USPS Ground Advantage) for shipping customers."
Dejoy says USPS is fit to handle any volume that may come from increased usage of Ground Advantage, but many shippers and logistics experts are skeptical - especially with massive delays already occurring in various parts of the country and the impending peak holiday season shipping rush.
And of course, consumers are likely to be left feeling the pinch as rates from all of the carriers continue to climb.
