Article · Finding clients
Cold email to local business prospects: what US law requires and a short template
For writing to a local business that has never heard of you: what the FTC's CAN-SPAM guide says applies, how to research the business from what it publishes, what never to claim, three short messages and a log for replies and opt-outs.
The short answer: a cold email that promotes your services is commercial email under US federal law, even when it goes to one business owner. It needs an accurate sender and subject, a line saying it is an advertisement, your postal address and a working opt-out that you honor within 10 business days. Write only to businesses you have actually looked at, mention one thing you saw and where, promise nothing about rankings, stop after three messages, and check that your email provider allows it at all.
Start with the reader's side
Google's page on hiring an SEO tells site owners to be wary of SEO firms and consultants that email them out of the blue, and to give unsolicited email about search engines the same skepticism as "burn fat at night" diet pills. It then reproduces a spam email of the kind Google says it receives too, telling google.com it is "not listed in most of the major search engines". Your email has to look nothing like that one.
Gmail's sender guidelines, written for email to personal Gmail accounts, say to send email only to people who want it, not to send messages to people who did not sign up, and not to buy addresses. A cold email is, by definition, a message to someone who did not sign up. If you send any, keep it small: a few businesses you have researched, one person at each, three messages at most.
The warmer routes are covered elsewhere: the other half of the job, a one-page website and a checklist lead magnet. Once someone has asked to hear from you, use the follow-up sequence for people who asked instead of this one. For introductions from clients who already know your work, see a client referral program.
What the FTC's CAN-SPAM guide says applies
The FTC's compliance guide says the law covers all commercial messages and, despite its name, does not apply only to bulk email. It is explicit about business email: "The law makes no exception for business-to-business email." What decides whether a message is commercial is its primary purpose. An email whose main job is to promote your SEO services is commercial, so a single message you write by hand to one owner is covered.
| Requirement | The FTC guide, paraphrased | In a cold email |
|---|---|---|
| Header information | "From", "To", "Reply-To" and routing information, including the originating domain name and email address, must be accurate and identify who sent the message. | Your own name, your business, an address on your own domain that you read. |
| Subject line | Must not be deceptive and must reflect what the message is about. | Say what the email is. No fake "Re:" or "Fwd:" suggesting an earlier conversation. |
| Identify it as an ad | Disclose clearly and conspicuously that the message is an advertisement. The law allows flexibility in how. | One plain line above your signature in every message. |
| Postal address | A valid physical postal address: a current street address, a post office box registered with the US Postal Service, or a private mailbox registered with a commercial mail receiving agency. | In every message. A registered box keeps your home address private. |
| Opt-out notice | Explain clearly how to opt out, by return email or another easy internet-based method, working for at least 30 days after sending. A menu of choices must include stopping all marketing email. | "Reply 'stop' and I will not email you again." |
| Honor opt-outs | Within 10 business days. No fee, no personal information beyond an email address, and no step beyond a reply or a visit to one web page. | Act the same or next business day. |
| Opted-out addresses | You may not sell or transfer them, even as part of a list, except to a company you hired to help you comply. | They go on your do-not-contact list and nowhere else. |
| Someone sends for you | You cannot contract away your legal responsibility. The business being promoted and the one doing the sending can both be held liable. | If an assistant or an outreach firm sends for you, you still answer for every message. |
The guide adds that your spam filter must not block opt-out requests, and that each separate email in violation can bring penalties of up to $53,088. Its list of conduct carrying criminal penalties, including imprisonment, includes harvesting email addresses and generating them through a dictionary attack, which it describes as sending to addresses made up of random letters and numbers in the hope of reaching valid ones. Copy each address by hand from the business's own website, and never guess at others.
The guide's list of requirements does not include asking permission before the first email. That does not make cold email welcome everywhere: mailbox providers and your own email provider set their own rules, as the next section explains, and other countries have their own laws.
A plain-language summary of the FTC's business guide, not legal advice. It covers US federal law only. If you write to businesses outside the US, check the rules where they are. For a specific situation, read the FTC guide itself or ask a lawyer.
A footer for every message
This email is an advertisement for my SEO services.
[Your name], [business name]
[Street address, registered PO box or private mailbox], [city], [state] [ZIP]
If you do not want more emails from me, reply "stop" and I will not contact you again.
Check your email provider's terms first
Your email provider's terms may not allow sending to people who have not opted in, so read them before you send. Read your provider's terms of service and acceptable use policy before your first cold email. If they forbid it, do not send it from that account.
Gmail's sender guidelines also require all senders to set up SPF or DKIM authentication for their sending domains, and add more requirements for anyone sending more than 5,000 messages a day to Gmail accounts. A handful of researched emails stays far below that threshold, but the SPF or DKIM requirement still applies.
Research a prospect honestly, from public information
Use only what the business publishes. Keep the research short, and write down what you saw, where and when.
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Read their website
What they sell, which area they serve, how a customer contacts them. Find the email address they publish for inquiries and copy it by hand, with the page URL. If the site lists only a contact form or a phone number, take that as your answer and do not hunt for a personal address.
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Look at their Business Profile as Google shows it
Search the business name on Google Search and Google Maps, where Google says people find local results. Note the name, category, hours, address or service area, reviews and photos. Google's local ranking help page says local results are mainly based on relevance, distance and how well known a business is, and that businesses with complete and accurate information are more likely to show up. A gap between profile and website, such as different hours, is a fact you can point to.
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Run one
site:searchSearch
site:followed by their domain. Google's SEO Starter Guide says results pointing to the site mean it is in Google's index. That is all it tells you; it is not a page count, a traffic estimate or an audit. -
Pick one observation, and check it is a real problem
Some things look wrong but are not. Google's guidelines tell service-area businesses, such as a plumber working from home, to hide their address, so a missing address may be correct. The same guidelines say unnecessary information in a business name, such as a marketing tagline, is not permitted and could lead to suspension of the profile. Mention it only if you can point to the words and the matching guideline.
Without access you cannot see their Search Console data, their profile's performance figures or their calls and leads, so say nothing about them. Do not pose as a customer or send a fake inquiry to test them.
Research worksheet (one per business)
Business and website: [name], [URL]
Contact address: [address] · found on: [page URL] · [date]
Profile checked on Search and Maps: [date]
Observation and where: [one sentence] · [URL or profile section]
Why it may matter: [one sentence, no promise]
Not checked: [Search Console, analytics, calls]
On my do-not-contact list? [yes / no]
What never to claim
A cold email is an ad. The FTC's advertising guide for small businesses says ads must be truthful and not deceptive, and that advertisers need proof before an ad runs, for implied claims as well as stated ones.
| Avoid | Why | Say instead |
|---|---|---|
| "I can get you to #1 on Google." | Google's hiring page says no one can guarantee a #1 ranking, and tells owners to find someone else if an SEO guarantees first place. | "Here is one thing I noticed and how it could be fixed." |
| "I can get you into the top three on Maps." | Google's local ranking help page says there is no way to request or pay for a better local ranking. | "Google says complete, accurate profiles are more likely to show up. Yours is missing [item]." |
| "A special relationship with Google" or "priority submit" | Google's hiring page names both as warning signs. | Leave it out. |
| "I ran a full audit of your site and found 47 errors." | A quick look is not an audit, and a number implies a check you did not do. The FTC's advertising guide asks for proof first. | "On [date] I looked at your public website and noticed one thing." |
| "Your site isn't showing up in search engines." | It is close to the claim in the spam email Google quotes on its hiring page. | Run a site: search first, and state only a specific, checked fact, with where you saw it. |
| "Your profile is about to be suspended." | You cannot know that. Google's guidelines say extra information in a business name could lead to suspension; they do not say it will. | "The name on your profile includes [words] that are not in the name on your website. Google's guidelines on business names may be worth a look." |
| "My clients get three times more calls." | It implies the reader will get the same. You would need proof, and it still would not predict their result. | What you do each month and how you report it. |
| Subject: "Re: our call" | There was no call. The FTC guide says subject lines must not be deceptive. | A subject that says what the email is. |
For the same rules applied to a written offer, see red flags to keep out of a proposal. For past client results you have permission to share, see results claims in a case study.
A three-message sequence
One observation on day 0, a fix plus one offer on day 5, a closing note on day 12. Send each yourself, one at a time, from your normal mailbox. Stop the moment someone replies, opts out or bounces. Keep each message short enough to read on a phone.
Message 1: one observation (day 0)
Subject: One thing I noticed on [business name]'s [website / Business Profile on Google]
Hi [first name, or "there" if the site gives no name],
I'm [your name], an SEO consultant in [city or area]. I work with [type of local business].
On [date] I looked at [business name]'s [website / profile on Google] and noticed one thing: [observation, and where you saw it].
[Why it may matter, in one sentence, with no promise.]
If it helps, I can send you a short written note on how to fix it, at no charge and with no call needed. Just reply "yes".
[Your name]
[Footer]
Message 2: something useful, and one offer (day 5)
Subject: How to fix the [item] on [business name]'s [website / profile]
Hi [first name],
Whether or not we ever work together, here is how to fix [the item] yourself: [step 1]. [Step 2]. [Step 3]. It takes about [time].
If you would rather have someone look after this and the rest of your local search setup, I offer [a fixed-price review / monthly local SEO] for [price]. Details: [link to your page].
[Your name]
[Footer]
The fix should work without you. That is the part of the email the reader can check, and it shows how you work. For a fixed-price offer to link to, see defining a fixed-price audit.
Message 3: close the loop (day 12)
Subject: Last note from me about [business name]
Hi [first name],
This is my last email about this. If now is not the right time, no reply is needed, and I will not email you again.
If you want to talk later, reply to this email or book a time here: [link].
[Your name]
[Footer]
Then stop, and keep that promise: no new sequence next month. For the page behind the booking link, see a booking page for SEO discovery calls.
Before you press send
- I looked at their site and profile myself, on the date in the email.
- The address is one they publish, copied by hand.
- The sender is me, and I read the reply address.
- The subject says what the email is.
- Ad line, postal address and opt-out line are in.
- No ranking promise, no number I cannot back up.
- Not on my do-not-contact list; my provider's terms allow it.
Reply handling and opt-out log
| The reply | What to do | When |
|---|---|---|
| "Stop", "remove me", "not interested", or annoyed | Stop all marketing email to them and add the address to the do-not-contact list. If you answer at all, one line confirming it, with nothing to sell. Do not argue. | Same or next business day; the FTC guide's limit is 10 business days |
| "Yes" or a question | Answer personally. Send the note you promised. From here it is a conversation, not a sequence. | Within one business day |
| "Not now, maybe later" | Ask whether they want you to get in touch on a date they choose. Only if they say yes, log the date. | Same day; then stop |
| "Where did you get my address?" | Say exactly where: the page URL from your worksheet. Offer to remove them. | Same day |
| Bounce | Mark the address dead. Do not try guessed variations. | Same day |
The log
One row per business, in a spreadsheet you check before every new email, including the ones you send next year.
| Business | Address and where found | Sent | Reply | Opt-out received | Opt-out applied | Status |
|---|---|---|---|---|---|---|
| Hypothetical: a bakery | hello@[domain], contact page, 3 Nov | 1: 3 Nov · 2: 8 Nov | "Please remove me", 9 Nov | 9 Nov, by reply | 9 Nov | Do not contact |
| [Business] | [address], [page], [date] | [1, 2, 3 with dates] | [date, type] | [date, how] | [date] | [open / conversation / closed / do not contact] |
An opt-out routine
- Each business day, check your inbox and your spam folder for replies. The FTC guide says your spam filter must not block opt-out requests.
- Apply every opt-out the same or next business day: move the row to "do not contact" and note the date and how they asked.
- Never email that address again unless they write to you first, and never sell or transfer the list. The FTC guide allows one exception: a company you hired to help you comply with the law.
- Keep the reply address working for well over 30 days after your last message.
After a yes
Send the note you promised, then move to a normal sales conversation. Google's hiring page says a good SEO asks what makes the business unique, who its competitors are, how search can help it and how customers find it; use those as your discovery call agenda. If they want a deeper look, the same page advises granting an SEO only read access to Search Console at the audit stage; what to put in an SEO audit covers which access to ask for. Someone who signs moves to the onboarding checklist.
Sources
- Not just bulk email; no B2B exception; primary purpose; message and opt-out requirements; no transfer after opt-out; responsibility when others send; spam filters; penalties; harvesting and dictionary attacks: CAN-SPAM Act: A Compliance Guide for Business (FTC)
- Truthful, non-deceptive ads; proof before an ad runs; express and implied claims: Advertising FAQ's: A Guide for Small Business (FTC)
- SEO firms that email out of the blue; "burn fat at night" diet pills; the quoted spam example; no guaranteed #1 ranking; "special relationship" and "priority submit"; what a good SEO asks; read access for audits (last updated 5 June 2026): Do you need an SEO? (Google Search Central)
- Local results on Google Maps and Search; mainly based on relevance, distance and how well known a business is; complete and accurate information; no way to request or pay for a better local ranking: Tips to improve your local ranking on Google (Google Business Profile Help)
- Unnecessary information, including marketing taglines, in business names not permitted and could lead to suspension; service-area businesses should hide their address (plumber example): Guidelines for representing your business on Google (Google Business Profile Help)
- What a
site:search shows: SEO Starter Guide (Google Search Central) - Scope (personal Gmail accounts); send only to people who want your messages and signed up; no purchased addresses; SPF or DKIM for all senders; the 5,000-a-day threshold: Email sender guidelines (Gmail Help)