If an email advertises or promotes the goods, services, or websites of more than one business, the law allows the advertisers [whose goods, services, or websites are advertised or promoted in the email] to designate one of the advertisers as the “sender” for purposes of complying with the Act as long as the designated advertiser or sender:
* meets the CAN-SPAM Act’s definition of “sender,” meaning that they initiate a commercial message advertising or promoting their own goods, services, or website;
* is specifically identified in the “from” line of the message; and
* comply with the “initiator” provisions of the Act, such as ensure the header and routing information is correct, a proper subject line is included as well as a valid postal address, and a working opt-out link.
If the designated sender doesn’t comply with the responsibilities the law gives to initiators, all advertisers in the message may be held liable as senders.
For operational guidance and structured compliance documentation tools, visit the CLIClaw Email Marketing Compliance Library.
This FAQ is provided for general informational purposes only and is not legal advice. It is intended as a starting point for understanding the issues discussed and should not be relied on as a substitute for advice from qualified legal counsel.
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