FAQ: Postal Sales Data for Comic Books
Those little boxes of fine print appearing in comics tell us
a lot about about comics history
by John Jackson Miller
The first Statement of Ownership with Circulation figures to appear in a comic book, from Archie #127 (1961).
One of the earliest ways comic book fans found out about comic book circulation was by following the data found in little boxes of fine print that appeared once a year in the comics themselves, usually in the winter. You can see some of the data collected from these "postal statements" in both the Postal Data section and in greater detail in our Title Spotlights section.
Q: When did circulation figures first appear in comics?
A: The Statement of Ownership, found in the most recent U.S. Code as Section 3685, Title 39 (it was once under Section 4369, Title 39), has been required of publishers who ship Second Class since the 19th Century. But it was in 1960 that it became the Statement of Ownership and Circulation, as that was the year that publishers were first required to list their average paid circulation for the year.
Q. What, specifically, does the law require publishers to print?
A: To quote the code...
"Each owner of a publication having periodical publication mail privileges shall furnish to the Postal Service at least once a year, and shall publish in such publication once a year, information in such form and detail and at such time as the Postal Service may require with respect to (1) the identity of the editor, managing editor, publishers, and owners; (2) the identity of the corporation and stockholders thereof, if the publication is owned by a corporation; (3) the identity of known bondholders, mortgagees, and other security holders; (4) the extent and nature of the circulation of the publication, including, but not limited to, the number of copies distributed, the methods of distribution, and the extent to which such circulation is paid in whole or in part; and (5) such other information as the Postal Service may deem necessary to determine whether the publication meets the standards for periodical publication mail privileges."
Q: Why did the government need to know all that?
A: In the early days of publishing magazines were often published by a maze of holding companies. Any publisher who abused the special postal rate would be liable, so the government wanted to know exactly who was responsible for each piece of mail that entered its system.
So that's why the "Ownership" needed to be stated. Another interesting reason can be found in a bit of the Code that still links to these postal rules today, having to do with the registration of "foreign propagandists" from before World War II. The Statement of Ownership would tell the government at a glance who owned the magazines entering the postal system.
Now, why did they decide they needed to know the circulations? As junk mail proliferated, the Postal Service aparently became concerned with abuse of the Second Class rate. With catalogs and other mailed material increasing in quantity, magazine publishers were made to swear that, yes, the publications they sent through the mail at the cheaper rate were, indeed, requested by the recipient. Knowing the number of subscribers told the Post Office how many there were. The government also got information as regards frequency.
That doesn't answer why they were interested in the overall circulation of the magazines, including the total print run and other channels of distribution. Possibly it had something to do with proving that the applicant was publishing a legitimate magazine. Whatever the reason, their presence in comic books is a happy historical event, as it gives us one of our few glances into the sales of earlier eras.
Q: Do comic-book publishers still file Statements of Ownership?
A: Today, Second Class is known as Periodical Class, and not many comics publishers use it — and some of those who do no longer publish the forms for some reason. DC stopped publishing data in 1988 because it had shifted to First Class, ending its need to file reports. Marvel, meanwhile, simply stopped publishing its reports in 2012; Archie, after many years of clockwork filings, seems to have skipped publishing its reports for 2016 in its 2017 comics. Most traditional magazine publishers continue to use the mailing class, so it continues to appear in Mad.
The image at right is from Archie Double Digest #266, published in 2016. As you can see, quite a lot more information appears in them.
You can find the latest version of the form publishers are required to fill out here.
Q: How valid is the information in comic book Statements of Ownership?
A: Validity differs from reliability in that it answers the question, "is this statistic really reporting what it says it is?" And whether Statements are telling the real sales truth has been a subject of debate for many years, since fans started collecting them in the 1960s as a means of figuring out which comics were selling the best. It's a federal crime to falsify the numbers — so, in theory, you might expect the information to be accurate. But there have been cases where negligence or misunderstanding led to errors in the Statements — and there have been many occasions where computational errors have crept in. (Easily rectified errors have been corrected for the Comics Chronicles reports.)
While there have been suspicions from time to time of publishers fiddling with their Statements to improve their numbers or because of apathy — Dick Giordano said that Charlton simply "made them up" during his editorship in the late 1960s — little evidence has been found of it being widespread, especially as other sources of comics circulation figures have become available for comparison. Gross exaggeration would have to be done uniformly across time and across several information channels not to be seen.
And, the filing of Statements is, again, a postal obligation, usually more of a bookkeeping afterthought than an opportunity to market a publisher's sales story. It's the advertisers who care most about how many copies publishers are selling — and those people are getting their information from audit bureaus, not the backs of comic books!
Q: How reliable is the information in comic-book Statements of Ownership?
A: As opposed to validity, reliability is more of a judgment about the measure itself: How well is it reporting what it says it is? The reliability of the Statements in the 1970s and onward is generally pretty good, given the comparisons I've been able to make with archival info from the publishers themselves. Looking at them across an entire year or range of years for a publisher, it's pretty easy to see when a figure is outside what we'd expect. Most tend to square up with other known sales figures fairly well. Errors, when they happen, generally tend to be computational in nature, involving transposition of numbers. But there are much bigger ones, resulting in complete data loss. Marvel once accidentally ran the previous year's form in Iron Man, for example. And in a handful of cases, the forms simply didn't appear at all for whatever reason — as was the case with Amazing Spider-Man in 1979.
Q: Has the Postal Service ever made a publisher correct previously published forms — or print omitted ones?
A: Yes. A magazine competitor of a publisher I worked for skipped printing its Statements several times, and each time, after our publisher complained to the Postal Service, the competitor was compelled to run its Statements.
For three years beginning in 1963, DC stopped publishing the actual sales figures in most of its comics. In 1965, after it had printed these "blank" Statements in its titles, DC returned to press several months later with forms that did include numbers. It's unclear whether DC was made to run the corrections, or whether it did it on its own. It's highly unlikely that DC intended to avoid printing the numbers — remember, it was very early in the period where publishers were obligated to print data — and so it may have been correcting the oversight. On the other hand, given the royal pain that setting up and running the forms represented, it's not illogical to imagine some outside influence in getting them run again.
Q: Do the Statements include digital sales?
A: In 2012, newspaper publishers — who care a lot about communicating how many readers they have — prevailed upon the Postal Service to add a section for reporting sales of electronic copies. It was several years before any publisher in comics reported anything, however; the first one appeared in Mad #543, reporting sales for 2016.
—Updated Dec. 18, 2017