Policy-Mandated Labels Such as "Adv:" in Email Subject Headers Considered Ineffective At Best
RFC 4096

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Network Working Group                                         C. Malamud
Request for Comments: 4096                           Memory Palace Press
Category: Informational                                         May 2005

     Policy-Mandated Labels Such as "Adv:" in Email Subject Headers
                     Considered Ineffective At Best

Status of This Memo

   This memo provides information for the Internet community.  It does
   not specify an Internet standard of any kind.  Distribution of this
   memo is unlimited.

Copyright Notice

   Copyright (C) The Internet Society (2005).

Abstract

   This memo discusses policies that require certain labels to be
   inserted in the "Subject:" header of a mail message.  Such policies
   are difficult to specify accurately while remaining compliant with
   key RFCs and are likely to be ineffective at best.  This memo
   discusses an alternate, standards-compliant approach that is
   significantly simpler to specify and is somewhat less likely to be
   ineffective.

Table of Contents

   1. Labeling Requirements ...........................................2
      1.1. Terminology ................................................3
   2. Subject Line Encoding ...........................................3
   3. Implementing a Labeling Requirement .............................5
   4. Subjects are For Humans, Not Labels .............................6
   5. Solicitation Class Keywords .....................................8
   6. Security Considerations ........................................10
   7. Recommendations ................................................10
   8. Acknowledgements ...............................................10
   9. References .....................................................11
      9.1. Normative References ......................................11
      9.2. Informative References ....................................11

Malamud                      Informational                      [Page 1]
RFC 4096              Policy Labeling Ineffective               May 2005

1.  Labeling Requirements

   The U.S. Congress and President have enacted the Controlling the
   Assault of Non-Solicited Pornography and Marketing Act of 2003
   (CAN-SPAM Act of 2003) [US], which requires in Section 11(2) that the
   Federal Trade Commission:

      "[transmit to the Congress] a report, within 18 months after the
      date of enactment of this Act, that sets forth a plan for
      requiring commercial electronic mail to be identifiable from its
      subject line, by means of compliance with Internet Engineering
      Task Force Standards, the use of the characters "ADV" in the
      subject line, or other comparable identifier, or an explanation of
      any concerns the Commission has that cause the Commission to
      recommend against this plan."

   The Korean Government has enacted the Act on Promotion of Information
   and Communication and Communications Network Utilization and
   Information Protection of 2001 [Korea].  As explained by the Korea
   Information Security Agency, the government body with enforcement
   authority under the act, Korean law makes it mandatory as of June,
   2003 to:

      "include the '@' (at) symbol in the title portion (right-side) of
      any commercial e-mail address, in addition to the words
      '(Advertisement)' or '(Adult Advertisement)' as applicable.  The
      inclusion of the '@' symbol, as proposed by the Korean government,
      is intended to indicate an e-mail advertisement.  Because e-mails
      easily cross international borders, the '@' symbol may be used as
      a symbol for filtering advertisement mails." [KISA]

   The State of Colorado has enacted the Colorado Junk Email Law, which
   states:

      "It shall be a violation of this article for any person that sends
      an unsolicited commercial electronic mail message to fail to use
      the exact characters "ADV:" (the capital letters "A", "D", and
      "V", in that order, followed immediately by a colon) as the first
      four characters in the subject line of an unsolicited commercial
      electronic mail message."  [Colorado]

   The Rules of Professional Conduct of the Florida Bar require, in Rule
   4-7.6(c)(3) states:

      "A lawyer shall not send, or knowingly permit to be sent, on the
      lawyer's behalf or on behalf of the lawyer's firm or partner, an
      associate, or any other lawyer affiliated with the lawyer or the
      lawyer's firm, an unsolicited electronic mail communication

Malamud                      Informational                      [Page 2]
RFC 4096              Policy Labeling Ineffective               May 2005

      directly or indirectly to a prospective client for the purpose of
      obtaining professional employment unless ... the subject line of
      the communication states 'legal advertisement.'"  [Florida]

   A subject line that complies with the above requirements might read