CIPP/US Study Guide
Chapter 11: Telecommunications and Marketing

The CAN-SPAM Act of 2003

CAN-SPAM governs commercial email to or from the U.S. on an opt-out basis: no false headers or deceptive subject lines, a working return address, a clear opt-out honored within 10 business days, and a valid physical postal address. Enforced mainly by the FTC, with penalties up to $50,120 per violation; it preempts most state email laws except those barring false/deceptive activity.

The CAN-SPAM Act applies to any entity advertising products or services by email directed to or originating from the U.S. It was not meant to eliminate all unsolicited email but to set 'rules of the road' on an opt-out basis.

  • Prohibits false or misleading headers and deceptive subject lines
  • Requires a functioning, clearly displayed return email address
  • Requires a clear opt-out notice with a cost-free opt-out mechanism
  • Prohibits sending to someone who opted out (after a 10-business-day grace period)
  • Requires clear identification as a commercial message (unless prior affirmative consent) and a valid physical postal address (a P.O. box is allowed)
  • Prohibits aggravated violations (address harvesting, dictionary attacks, automated account creation, retransmission through unauthorized accounts)
  • Requires a warning label on sexually oriented material (unless prior affirmative consent)
Enforcement and preemption

Enforced primarily by the FTC (plus other federal regulators and state AGs); penalties up to $50,120 per violation. ISPs adversely affected may sue for injunctive relief and damages up to $250 per violation (max $2 million, trebled for willful/aggravated conduct). CAN-SPAM preempts most state email laws - except those that prohibit false or deceptive activity. There is no general private right of action for individuals.

Commercial vs. transactional

The opt-out and labeling rules apply to commercial messages (primary purpose advertising/promotion), not to Transactional or relationship messages like order confirmations, warranty/safety notices, or employment/benefit information.

Key terms - quick answers

What is “CAN-SPAM Act”?
The Controlling the Assault of Non-Solicited Pornography and Marketing Act of 2003, governing commercial email directed to or originating from the U.S.
What is “Transactional or relationship message”?
A message whose primary purpose is to facilitate a transaction, provide warranty/safety info, give info about an ongoing relationship, address employment/benefits, or deliver goods/services already owed - not subject to the commercial-email rules.
What is “Sender”?
Anyone who initiates a commercial email and whose product or service is advertised; the 2008 rule lets the entity in the 'from' line be treated as the single sender if other provisions are met.