Subject: [Asrg] 6. Proposals -- Second revision of spam-labeling draft proposed RFC

From: "Eric S. Raymond" <[email-masked]>
Date: Wed, 26 Nov 2003 16:03:02 -0500

This version addresses all technical and editorial issues raised in
the group thus far.  The "Keywords" header has been changed to
"Sender-Keywords" in light of Jacob Pame's recommendation.  References
to U.S. law have been internationalized.  The Rationale has more
material addressing various issues and objections.

---------------------------------------------------------------------------
Anti Spam Research Group                                    Eric Raymond
Internet-Draft                                    Open Source Initiative
Expires: XXXX XX, 2004                                       Nov 26 2003

          Requirements for Advertising and Bulk Email

Status of this Memo
 
 This document is an Internet-Draft and is in full conformance with
 all provisions of Section 10 of RFC2026.
 
 Internet-Drafts are working documents of the Internet Engineering
 Task Force (IETF), its areas, and its working groups.  Note that
 other groups may also distribute working documents as
 Internet-Drafts.
 
 Internet-Drafts are draft documents valid for a maximum of six
 months and may be updated, replaced, or obsoleted by other
 documents at any time.  It is inappropriate to use Internet-
 Drafts as reference material or to cite them other than as
 "work in progress."
 
 The list of current Internet-Drafts can be accessed at
 http://www.ietf.org/ietf/1id-abstracts.txt.
 
 The list of Internet-Draft Shadow Directories can be accessed
 at http://www.ietf.org/shadow.html.
 
 This Internet-Draft will expire on XXXX XX, 2004.

Copyright Notice
 
 Copyright (C) The Internet Society (2003).  All Rights
 Reserved.

Abstract

 This Internet-Draft describes standards for labeling of commercial
 and bulk email.

1. Introduction

 The "CAN-SPAM Act of 2003" [CAN-SPAM] amends U.S. Federal law 
 to read in part (11.2):
 
    The Commission shall transmit to the Senate Committee on
    Commerce, Science, and Transportation and the House of
    Representatives Committee on Energy and Commerce--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
    the plan.

 The IETF accepts this as a request to develop a technical
 recommendation for requirements on commercial email that will
 support the purposes of the Act.

2. Definitions

 The key words "MUST", "MUST NOT", "REQUIRED", "SHALL", "SHALL
 NOT", "SHOULD", "SHOULD NOT", "RECOMMENDED", "MAY", and
 "OPTIONAL" in this document are to be interpreted as described
 in [RFC2119].

 For purposes of this RFC, "commercial email" is email sent for
 the purpose of advertising a product or service, but not
 including transactional or relationship messages.  See CAN-SPAM
 Section 3.2.

 For purposes of this RFC, "bulk email" is mail duplicated to a
 list of one hundred (100) or more recipients in substantially
 identical form; that is, such that the variations do not affect
 the meaning of the mail as it is read by a human being.

 For purposes of this RFC, "porn email" is mail which either
 contains pornographic content or which offers access to such
 material.  In U.S. jurisdictions, the relevant legal definition
 is section 2256 of title 18, United States Code.

3  Labeling methods

3.1  The ADV convention

 Commercial email from reputable firms is often labeled with the
 prefix "ADV:" in the Subject header.  

 This has the advantage of being readily visible, because
 effectively all mail readers display mail subject lines in their
 summary views.  It has the disadvantage that, because of the way
 many mailreaders generate reply subject lines, the label may
 persist in replies where it is not appropriate,

3.2  The Sender-Keywords header

 The Sender-Keywords header contains keywords describing the content
 of the mail.  Keywords are separated by whitespace and/or commas.
 For purposes of conformance to the requirements of [CAN-SPAM], the
 following keywords are defined:

    advertising     Applicable to any commercial email

    bulk            Applicable to any bulk email

    porn            Applicable to any porn email

 The Sender-Keywords is a necessary part of the sender's compliance with
 [CAN-SPAM] and SHOULD NOT be removed or rewritten by relaying systems,
 MTAs, or MUAs

4. Opt-out support

 The List-Unsubscribe header, defined in [RFC2369], supports list
 unsubscription via mechanisms including: 
 
     (a) a mailto: URL with the property that sending
         mail to it unsubscribes the sender.

     (b) a URL to a page where the user may enter an
         address to be unsubscribed.

 The presence of these mechanisms fulfills the requirements of
 [CAN-SPAM] 5.3.

5. Accountability and transparency

 The List-Owner header, defined in [RFC2369], specifies a
 responsible list administrator to cope with situations in whicch
 the List-Unsubscribe mechanisms are inadequate or temporarily
 faulty.

 The List-Owner header is optional and may be omitted if the
 responsible person is the postmaster of the originating system.

6.  Conformance requirements

 These conformance requirements directly address the legal
 requirements of [CAN-SPAM], and will constitute the Internet
 Engineering Task Force's recommendation to the Federal 
 Trade Commission as solicited in section 11.2.

 Commercial electronic mail MUST be labeled using at least one of
 either the ADV: Subject-line prefix or the token "advertising" in
 a Sender-Keywords header.

 Bulk email MAY be labeled with the token "bulk" in a Keywords
 header.  Commercial bulk email MUST be so labeled.

 Porn email MAY be labeled with the token "porn" in a Keywords
 header.  Commercial porn email MUST be so labeled.

 Commercial bulk email MUST include a List-Unsubscribe header
 implementing the RFC2369 proposal.

 Commercial bulk email SHOULD, if the responsible sender is not the
 postmaster of the originating system, include a List-Owner
 header implementing the RFC2369 proposal.

7. Rationale

 In the interests of making adoption as rapid and painless as
 possible, this RFC extends and codifies existing practice rather
 than inventing new mechanisms.

 ADV: by itself is not sufficient.  The user's MUA might render
 the Subject line in a CJK or other encoding in which the characters
 "ADV:" don't exist.

 The temptation to design a classification system for
 advertising, permitting more exact labeling than "ADV:", is
 strong.  However, no such elaborate system is required by
 [CAN-SPAM], and were we to invent one it might in fact be
 unenforceable under the Act.  Furthermore, the boundaries of
 such a system would be a subject of endless dispute, both during
 design and after implementation.

 The conformance requirements have been designed to have minimal
 impact on individual mail senders, maximal impact on commercial bulk
 mailers.  In particular, the guidelines on labeling non-bulk mail in
 the "advertising" and "porn" classes are written with MAY rather than
 SHOULD because the spam problem isn't caused by one-to-one
 communication.

 Internationalization was considered.  With a total inventory of four
 tokens intended to be maxhine-readable (rather than presented
 directly to humans), the benefits seem small and the added complexity
 of a multilingual vocabulary rather pointless.

6. References

[CAN-SPAM] "An Act to regulate interstate commerce by imposing
           limitations and penalties on the transmission of
           unsolicited commercial electronic mail via the
           Internet".  S.877, passed the U.S. House or 
           Representatives on 21 Nov 2003.

[RFC2119]  "Key words for use in RFCs to Indicate Requirement
           Level"; Scott Bradner.

[RFC2822]  "RFC 2822 - Internet Message Format"; Peter Resnick
           (Editor).

[RFC2369]  "The Use of URLs as Meta-Syntax for Core Mail List
           Commands and their Transport through Message Header
           Fields"; Joshua D. Baer & Grant Neufeld.

Authors' Addresses
 
 Eric S. Raymond
 Open Source Initiative
 6 Karen Drive,
 Malvern PA 19355
 US
 
 EMail: [email-masked]
 URI:   http://www.catb.org/

Full Copyright Statement
 
 Copyright (C) The Internet Society (2003).  All Rights
 Reserved.
 
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 organizations, except as needed for the purpose of developing
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 PARTICULAR PURPOSE.

Acknowledgements
 
 Funding for the RFC Editor function is currently provided by
 the Internet Society.
-- 
		<a href="http://www.catb.org/~esr/">Eric S. Raymond</a>

  "...quemadmodum gladius neminem occidit, occidentis telum est."
[...a sword never kills anybody; it's a tool in the killer's hand.]
        -- (Lucius Annaeus) Seneca "the Younger" (ca. 4 BC-65 AD),

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