Legal Definitions - Table 1: Overarching Anti-Spam Frameworks in the United States, Canada, and the European Union

The table above provides a quick comparison of the anti-spam frameworks in the United States, Canada, and the European Union. The table includes information on the laws, recipient opt-in versus opt-out regime, primary regulator, private right of action, and relationship to local law.

For example, the United States follows an opt-out regime, which means that companies can send commercial emails unless the recipient explicitly requests to be removed from the mailing list. In contrast, Canada follows an opt-in regime, which means that companies must obtain explicit consent from the recipient before sending commercial emails. The European Union also follows an opt-in regime, but the implementation of this regime depends on the member state.

Another example is the primary regulator. In the United States, the Federal Trade Commission is responsible for enforcing the CAN-SPAM Act of 2003. In Canada, the Canadian Radio-television and Telecommunications Commission is responsible for enforcing the Canadian Anti-Spam Law of 2010. In the European Union, each member state has its own national regulatory authority.