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

The goal of this table is to provide at-a-glance information enabling rough comparison among the overarching anti-spam frameworks in the United States, Canada, and the European Union. The reader is encouraged to consult the linked materials for more precise information.

	United States	Canada	European Union
Laws	CAN-SPAM Act of 2003	Canadian Anti-Spam Law of 2010	E-Privacy Directive (2002/58/EC)
Recipient Opt-In Versus Opt-Out Regime	Opt-Out	Opt-In	Opt-In
Primary Regulator	Federal Trade Commission	Canadian Radio-television and Telecommunications Commission	National Regulatory Authorities
Private Right of Action	Only for “internet access service” providers	Yes	Depends on Member State implementing legislation
Relationship to Local Law	Preempts most state laws relating specifically to commercial email	Establishes minimum standards that provinces and territories may exceed	Directs member states to enact implementing laws

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

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