The rulebook for sending commercial email in America — and the price of ignoring it.
The law reaches any message whose primary purpose is commercial — a promotion, a sale, a product announcement. There is no exemption for business‑to‑business mail. A note to a former customer about a new product line counts just as much as a cold marketing blast. Purely transactional or relationship messages (receipts, shipping updates, account notices) are treated separately and carry lighter obligations.
The “From,” “To,” “Reply‑To,” and routing information must accurately identify who sent the message. No spoofed senders, no disguised origins.
The subject must reflect the actual content of the message. A subject promising one thing while the body sells another is a violation.
Identify the message as an advertisement. The law gives flexibility on how, but the commercial nature has to be clear and conspicuous.
Every commercial email must contain a valid postal address — a street address, a registered P.O. box, or a private mailbox registered with a commercial mail agency.
Provide a visible, easy‑to‑use unsubscribe mechanism. It must stay functional for at least 30 days after the message is sent.
≥ 30 days · must workProcess an unsubscribe request within 10 business days. You can’t charge a fee, require extra information, or make the recipient do anything beyond sending a reply or visiting one page.
≤ 10 business days · no feeHiring an agency doesn’t transfer responsibility. Both the company whose product is promoted and the company that sends the mail can be held legally accountable.
Penalties are assessed per email, not per campaign. There’s no cap tied to company size — a five‑person startup faces the same per‑message structure as a multinational.
The FTC states plainly that the law makes no exception for business‑to‑business messages. A cold sales email to a company inbox is covered.
Each sender and each line of business has its own obligations. Recipients must be able to opt out of the specific mail they’re receiving.
Opt‑out must be free and frictionless. No fees, no logins, no requiring personal details beyond an email address.
Outsourcing the sending doesn’t outsource the responsibility. The promoted brand stays on the hook alongside the mailer.