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May 2007

Ask ABC: What Paragraph 3 newspaper data do I need to send to ABC?

The data in Paragraph 3 of a newspaper Audit Report to be provided by the newspaper, is an analysis of geographic distribution for one representative date in the audit period. Paragraph 3 data is required for all U.S. newspapers. Publishers must also compile data for either Paragraph 3A, 3B or both.

ABC rules require that Paragraph 3 data be prepared in advance of the auditor’s arrival and sent to ABC before the audit. If you have not already provided your Paragraph 3 data or discussed it with your field auditor or technical review staff, please send the data to:


Hard Copy/CD-ROM:
Audit Bureau of Circulations
Att: Doreane Luszczewski
900 N. Meacham Road
Schaumburg, IL 60173

(with attached Microsoft® Excel® file)

If you have any questions, please contact your Audit Manager.

Paragraph 3

Paragraph 3 is required for all U.S. newspapers. It details circulation by county for those counties with more than 25 copies distributed on the analysis date. If a county has less than 25 copies, it is categorized under the “Miscellaneous Counties” heading.

The analysis is compiled by two dates—one Monday through Friday date and one Sunday date. Publishers select the dates for the analysis, but the dates do need to be representative of the audit period.

Publishers report the following circulation categories by actual gross distribution within Paragraph 3 (for the Sunday and daily analysis date separately):

  • Individually Paid
  • Other Paid
  • Total Core Newspaper
  • Electronic Editions
  • Unique Editions
  • Total Paid

A prototype of the newspaper Audit Report is available on ABC’s Web site (PDF).

Paragraph 3A

Paragraph 3A is an optional reporting category. If a publisher chooses not to report Paragraph 3A data, they must report Paragraph 3B data. Publishers can report data for both Paragraphs 3A and 3B.

Paragraph 3A details circulation by town for those towns with more than 25 copies distributed on the analysis date. If a town has less than 25 copies, it is categorized under the “Balance in County” heading. The list should be compiled in alphabetical order by county.

The analysis is compiled by the same two dates—one Monday through Friday date and one Sunday date—as the data in Paragraph 3.

Publishers report the following circulation categories by actual gross distribution within Paragraph 3A (for the Sunday and daily analysis date separately):

  • Individually Paid
  • Other Paid
  • Total Core Newspaper
  • Electronic Editions
  • Unique Editions
  • Total Paid

A prototype of the newspaper Audit Report is available on ABC’s Web site (PDF).

Paragraph 3B

Paragraph 3B is also an optional reporting category. If a publisher chooses not to report Paragraph 3B data, they must report Paragraph 3A data. Publishers can report data for both Paragraph 3A and 3B.

Paragraph 3B details circulation by ZIP code for those ZIP codes with more than 25 copies distributed on the analysis date. If a ZIP code has less than 25 copies, it is categorized under the “Miscellaneous ZIP Codes” heading. The list should be compiled in ascending numerical order.

The analysis is compiled by the same two dates—one Monday through Friday date and one Sunday date—as the data in Paragraph 3.

Publishers report the following circulation categories by actual gross distribution within Paragraph 3B (for the Sunday and daily analysis date separately):

  • Individually Paid
  • Other Paid
  • Total Core Newspaper
  • Electronic Editions
  • Unique Editions
  • Total Paid

A prototype of the newspaper Audit Report is available on ABC’s Web site (PDF).

Tips for Preparing Paragraph 3 Data

  • Make sure that your data is compiled by the point-of-delivery address to the newspaper recipient, not by the carrier, agent or distributor addresses.
  • Newspapers choose the dates for the analysis, but the dates must be representative of the audit period.
  • Maintain all of the records and worksheets you used to prepare the Paragraph 3 data, including mail galleys, route lists, retail account invoices and distributor surveys. These records must be made available to the auditor upon request.
  • Double-check your math and ensure that the numbers reported in the total circulation columns in Paragraphs 3, 3A and 3B are the same. Also, take a few minutes to run basic mathematical checks to ensure your formulas are correct.
  • Finally, make sure that the numbers reported in the total circulation columns match to the total circulation reported in your circulation ledger.


Related Links:
ABC Newspaper Audit Report Prototype (PDF)
Rule C 7.12 List of Towns Receiving 25 or More Copies
Audit Prep Checklist

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