EU

ePrivacy: Direct Marketing Rules

Direct Marketing Rules [Art 13]

Rule: Electronic marketing (email, SMS, automated calls) requires prior opt-in consent, with a “soft opt-in” exception for existing customers.

The Basic Rule: Opt-In Required [Art 13(1)]

The use of automated calling and communication systems without human intervention (automatic calling machines), facsimile machines (fax) or electronic mail for the purposes of direct marketing may be allowed only in respect of subscribers or users who have given their prior consent.

Soft Opt-In Exception [Art 13(2)]

You may send marketing emails WITHOUT prior consent if ALL conditions are met:

  1. Existing customer relationship — You obtained the email in the context of a sale
  2. Similar products/services — Marketing your own similar products only
  3. Clear opt-out at collection — Customer was given opportunity to object when email was collected
  4. Easy opt-out in every message — Free and easy unsubscribe in each communication

What Counts as Direct Marketing?

IncludedNot Included
Promotional emailsTransactional emails (order confirmations)
SMS marketingService messages (password resets)
Automated callsCustomer service calls
Fax marketingRelationship surveys (debatable)
Push notifications (marketing)Administrative notifications

B2B vs B2C

The Directive allows Member States to choose whether Art 13 applies to:

  • Legal persons (B2B) — Some countries (UK, Germany) allow opt-out model for B2B
  • Natural persons (B2C) — Always opt-in required

Check national implementation for B2B rules.

Requirements for All Marketing

Regardless of consent basis:

  1. Identity must be clear — Sender identity not concealed or disguised
  2. Valid return address — Must provide address for opt-out requests
  3. Opt-out honored — Must respect unsubscribe requests

Penalties

Enforcement is at national level. Examples:

  • France: Up to €75,000 per violation
  • Spain: Up to €150,000
  • Germany: Up to €300,000

Comparison with CAN-SPAM (US)

AspectePrivacy (EU)CAN-SPAM (US)
Default modelOpt-inOpt-out
Prior consentRequiredNot required
Soft opt-inYes, for existing customersN/A (always allowed)
B2BVaries by countrySame as B2C

Citation

Article 13, ePrivacy Directive

Contains public sector information licensed under the Open Government Licence v3.0 where applicable. This is not legal advice. Always refer to official sources for authoritative text.

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