Max Heath clarification on free distribution qualifying for periodical status
A free paper may qualify for Periodical rates if more than half can be shown to have requested it, as below, and operate with these stipulations. Qualifying for requesters can be a lengthy and ongoing process. I have a column at the office I can forward you if desired on some details.
If it can't meet these standards, it would have to be mailed Standard Mail, especially if it's an all-ad medium.
6.4 Requester Publications
6.4.1 Basic Standards
A publication, whether circulated free or to subscribers, may be authorized to be mailed at the Outside-County Periodicals rates if it meets the basic standards in 4.0 and:
a. Each issue contains at least 24 pages.
b. No issue contains more than 75% advertising (as defined in 4.12).
c. The publication is not owned or controlled by one or more individuals or business concerns and conducted as an auxiliary to and essentially for the advancement of the main business or calling of those who own or control the publication.