Monitored Free Distribution - Consumer Magazines

Back to index

Monitored Free Distribution [Print only]

Copies distributed on a regular and consistent basis to known distribution points for pick up or receipt by consumers.

Principles

1. Prior notification of distribution details and any changes to ABC

2. Distribution follows a regular and consistent pattern to known distribution points

3. Copies are made available at the known distribution points for pick up or receipt by consumers

4. Quantity claimed should not exceed potential demand by the intended consumers

5. Effective management controls over distribution

Requirements 

1. Prior notification of distribution details and any changes to ABC

1. You must inform ABC before the distribution of the first issue for which you intend to claim monitored free distribution copies, including the following information:

   1.  Details of how, when and where the copies will be distributed. 

   2. A list of all distribution points .

2. You must, on an on-going basis, be able to provide ABC on request, details of current and historical distribution points, quantities and distribution dates.

3. The monitored free distribution element of any claim must be audited by ABC Staff Auditors.

Guidance Available

2. Distribution follows a regular and consistent pattern to known distribution points  

1. A distribution point is defined as an agreed location at which copies are handed to or left for pick up by the consumer. 

2. Distribution points used must be regular in type for every issue (subject to notified and allowable changes). 

   1. If there are changes to the type of distribution points used (whether a new type is added or an existing type is dropped) then you must inform ABC.

   2. We will consider the nature and extent of the changes in the distribution and decide if any further action is required. For example being required to notify advertisers of the changes or the issuing of a new Certificate.

   3. For the avoidance of doubt, a particular distribution must be on an every issue basis to be considered regular for this category (meaning, for example, that distribution every other issue is not regular).

3. The distribution points claimed must be consistent with the overview description.

4. ABC must have the right to visit or contact distribution points for verification purposes.

5. It is recognised that there will be minor changes in distribution. However significant changes must be notified as follows:

   1. If the total monitored free distribution for an issue increases by more than 25% compared to the average monitored free distribution of the previous four issues you must apply to ABC for approval to claim the additional copies.

   2. If the total monitored free distribution for an issue decreases by more than 25% compared to the average monitored free distribution of the previous four issues you must notify ABC of the change.
      
      Note:

1. 1. • We will consider the nature and extent of the changes in the distribution and decide if any further action is required. For example being required to notify advertisers of the changes or the issuing of a new Certificate.

      • If your publication has a defined publishing frequency and publishes a double issue (for example: a monthly publication publishes a July/August issue) then it may be acceptable to claim an increase in supply for that issue to cover the extended pick up period before the next issue is distributed.

      • If your publication has a seasonal audience then it may be acceptable to increase or decrease regular supplies in line with the increased or decreased potential audience for the title. The in-season and out-of-season supplies must be regular in quantity and distribution point types, and the seasons must be clearly defined in the overview description and agreed in advance by ABC.

      • If there are less than 4 issues of the publication distributed in a calendar year then the increases or decreases in monitored free distribution (of more than 25%) will be assessed against the average monitored free distribution of the issues distributed in the previous 12 months.

Guidance Available

3. Copies are made available at the known distribution points for pick up or receipt by consumers

1. You must be able to provide evidence, from the third party responsible, of the number of copies of the publication made available for pick up or receipt at each distribution point by consumers. Note:

   1. Where the copies are made available for pick up or receipt at distribution points by drivers/distributors that are not 3rd party to the publisher (such as in-house distributors or from a joint venture), it may be possible to include these in the claim as long as:

      • It can be demonstrated that the drivers/distributors have sufficient independence and are specifically contracted to deliver/distribute the publication.

      • The auditor/ABC has full and unrestricted access to the relevant parties' documentation and financial records.

      • ABC has specifically agreed this distribution method.

   2. In the case of retail customer magazines it may be acceptable for the publication to be distributed through the same distribution system from central/area warehouse to individual retail outlets as the retailer’s other goods and use associated documentation to support a gross distribution claim and EPOS reports for net distribution if applicable . A retail customer magazine is defined as a publication which:

      • Is published by or on behalf of a retailer

      • Is targeted at customers of that retailer

      • Is supplied to the retailer’s own outlets for distribution in store

   3. In the case of copies distributed to third party distributors for onward distribution to airlines (for airplanes and/or lounges), trains or ships:

      • Copies may be claimed as gross distribution providing ABC is given full and free access to the distributor’s contractual arrangements, invoices and documentation to enable verification of the onward supply.

      • The gross distribution claim must be restricted to the quantity verified as onwardly distributed to the airlines, trains or ships and not the quantity supplied to the distributor.

   4. In the case of copies that are not distributed solus but are packaged with other free or paid publications, inserted in other publications or in goody bags you must be able to demonstrate the copies are distributed using that mechanic. This may include providing evidence of insertion, packaging, sales etc. We recommend you contact us for advice on evidence required.

      •  If free copies are distributed via a retail multipack with a paid publication the claim should be restricted to the paid publication’s net sale. If at the time you submit your circulation claim unsold copies could still be returned or reported you must make an estimate of the final net sale. You must adjust your claim in the following period to reflect any difference between the estimated net sale and the actual net sale.   

2. Where your ABC monitored free distribution claim is for the net number of copies picked up or received by consumers at a distribution point, you must be able to provide evidence of the number of copies returned/not picked up at each relevant distribution point. Note: This must be on a ‘session’ basis. For example a hand merchandiser who goes out first thing in the morning and then again after lunch with a new supply of copies must sign separately for the morning and afternoon supply and returns.

3. You cannot claim distribution of back issues, with the exception of
   1. copies distributed overseas, where copies may be claimed providing they are distributed within the relevant on-sale period for the current issue for the territory concerned.
   2. repurposed unsold retail copies – see below.

Repurposed unsold retail copies (from January 2023)
Repurposed unsold retail copies are print copies supplied to wholesale/retail for retail sale, but which have been returned unsold and are subsequently sold or distributed in accordance with these standards. For the avoidance of doubt, these copies cannot be claimed more than once.

You may claim back issues of repurposed unsold print retail copies as follows:

1. For publications publishing fewer than 18 issues in a calendar year – issues up to 6 months old against the issue current at the time of sale/distribution.

2. For publications publishing 18 or more issues in a calendar year – issues up to 3 months old against the issue current at the time of sale/distribution.

3. The level of repurposed copies included in your claim must be reported – see the Reporting section below for details.

Guidance Available

4. Quantity claimed should not exceed potential demand by the intended consumers

1. Any distribution carried out by merchandisers must be claimed on a net basis (i.e. account for undistributed copies) at each distribution point.

5. Effective management controls over distribution 

1. The publisher is responsible for ensuring that the copies they claim have been delivered and if applicable returns/copies not picked up are accounted for. This requires a publisher to have appropriate management controls and processes in place to ensure that this is happening. 

Guidance Available

Reporting

You will report monitored free distribution copies as follows, which will be broken out on the ABC Certificate: 

1. By geographical type:

1. United Kingdom and Republic of Ireland

2. Other Countries

2. By total average monitored free distribution over the Reporting Period, combined with other free copy categories, analysed into:

a) Regular
- Net
- Gross

3. By total average monitored free distribution per issue for the period, analysed into:

a) Net distribution - by hand

b) Net distribution – other

c) Gross distribution

4. By total average monitored free distribution per issue analysed by the following distribution point types, analysing copies by those distributed solus or packaged with other products:

1. Airports, airlines, international rail

2. Cruise ships / ferries 

3. Trains / other travel points

4. Hotels

5. Retail outlets

6. Food and drink outlets

7. Street

8. Educational establishments

9. Medical establishments

10. Offices

11. Leisure centres / clubs

12. Events

13. Other publication insert

14. Other
    
    A breakdown of the total average Monitored Free Distribution packaged copies broken out by a description of the accompanying product and distribution mechanism. 
    
    For example: 
    
    Packaged copies:
    500 copies distributed at hotels with XYZ magazine.
    1,213 copies packaged with PQR magazine in a retail multipack

5. You may optionally report the total average number of distribution points per issue over the period.

6. A verifiable overview description of the Monitored Free Distribution.

7. If you have claimed repurposed unsold retail copies, then you must combine the repurposed copies with any other repurposed copies in other categories and report the total as a percentage of the total average circulation for the reporting period.

Guidance

G1. Prior notification of distribution details to ABC

1. The overview description must be verifiable from evidence.

2. The list of all distribution points. We would expect this to include the following for each distribution point: 

   • Unique point ID (to enable clear identification when changes are made).
   • Address, including postcode.
   • Audience Type. For example airside/international rail, hotel – as analysed on the Certificate.
   • Whether there is a responsible individual based at the point, a deliverer places copies on display, or it is a hand distribution point.
   • Point description. For example: type of bin, location at address.
   • Point restrictions. For example it is particularly important to identify any points which can only be accessed via security barriers such as airport airside locations, some office buildings.
   • Name of responsible person:
   1. • Name of recipient for distribution points where individual based at point confirms delivery.
      • Name of deliverer (in-house or name of delivery company) where deliverer confirms delivery.
   • Telephone number of responsible individual.
   • Normal day/date of delivery.
   • Approximate time of delivery.
   • Method of delivery. For example: name of 3rd party distribution company.
   • Normal supply quantity.
   • Normal day/date of collection of returned/damaged copies (net copies only).
   • Additional details as above for all regular top-up supplies
     
     The list of all distribution points must be supplied on request.  

3. Other information needed for audit typically will include:

   1. Issue by issue monitored free distribution summary: This is an issue by issue summary of the claimed monitored free distribution compiled from the Detailed Issue Distribution Lists (see below).

   2. Detailed Issue Distribution List: This form includes on an issue by issue basis:

      • Name/identification of distribution point
      • Type of distribution point (e.g. hotel), manned or unmanned
      • Gross supply
      • For copies claimed on a net basis:Returned/damaged copies
      • Net distribution
      • Actual day/date of delivery

      • For copies claimed on a net basis: Actual day/date of collection of returned/damaged copies

4. Copies that are purchased from distribution points are still eligible as monitored free distribution as long as they comply with the monitored free distribution rules. 

G2. Distribution follows a regular and consistent pattern to known distribution points

1. A distribution point is defined as an agreed location at which copies are handed to or left for pick up by the consumer. 

   1. You should be able to provide details of the terms and conditions between the publisher and the distribution points for the supply and collection of copies, including any financial arrangements. 

2. Examples of ineligible distribution (because it is not regular and consistent) include distribution to irregular exhibitions, rotational sampling, and variations in gross supply due to fluctuations in demand (except as allowed due to seasonal variation rules).  Such copies may be claimed as Sample Free Distribution.

G3. Copies are made available at the known distribution points for pick up or receipt by consumers

1. You must be able to provide evidence, from the third party responsible, of the number of copies made available for pick up or receipt at each distribution point by consumers. 

   1. Typically, suitable evidence will be a delivery note signed and dated by a responsible third party individual (at the time of delivery) confirming the number of copies of the particular issue of the publication supplied and that they have made available for pick up or receipt at the particular location.

   2. Where the individual confirming the delivery is the driver/distributor, additional verification such as the deliverer’s manager signing to confirm completion, or the inclusion of a time of delivery may be required where ABC deems appropriate for audit purposes. 

   3. Ordinarily an individual based at the distribution point should be signing the delivery note at the time of the delivery. However if the signatory is unavailable at the time of delivery they can complete the delivery note left with the consignment and return to the publisher within 5 working days or before the distribution of the next issue (whichever is the sooner).

2. Where your ABC monitored free distribution claim is for the net number of copies picked up or received by consumers at a distribution point, you must be able to provide evidence of the number of copies returned/not picked up at each relevant distribution point.

   1. Typically, suitable evidence will be a returns note signed and dated by a responsible third party individual (at the time of collection) confirming the number of copies of the publication returned/not picked up, including the time collected. If there is no evidence you cannot assume 100% distribution but instead due to lack of evidence must treat distribution as zero.

   2. Ordinarily an individual based at the distribution point should be signing the returns note at the time of the collection. However if the signatory is unavailable at the time of collection they can complete the returns/collection note left at the time of collection and return to the publisher within 5 working days or before the distribution of the next issue (whichever is the sooner). 

   3. Distributors and their agents must not have a disincentive to accurately report the net number of copies picked up/received by consumers.

G5. Effective management controls over distribution

1. For each publication the detail and extent of these controls and processes will vary as they should be appropriate to the type of distribution. These could include training of staff, spot checks, customer complaint handling etc. 

   1. These controls and processes are reviewed by ABC as part of the joining process and continuing audit of a publication. These help underpin the audit in that they form part of the consideration of risk and consequently the type and extent of audit work done.

   2. If weaknesses in management controls are found during the audit work, the publication’s circulation auditor / ABC will inform the distributor and the publisher of defined improvements to be implemented and a timescale to ensure copies are still eligible for ABC purposes.