B2B email marketing in Germany: review permission before sending

Email planning starts with whether you may send the message, not with a proposed sequence or response-rate target. This guide provides operational questions to take to the people responsible for legal and privacy review; it is not a determination that a particular campaign is lawful.

Separate data processing from permission to send

Germany’s UWG section 7 addresses advertising by electronic mail and generally requires prior express consent, with a limited existing-customer exception subject to conditions. A B2B address is not a blanket exemption. Check the current official German text of section 7 with qualified counsel before relying on an exception.

DSGVO is the German name for the GDPR. A data-processing basis under the GDPR does not by itself settle whether a marketing email may be sent. The European Commission’s GDPR guidance also points to the separate rules governing electronic direct marketing.

Build an inspectable contact record

Before importing a list, establish where each record came from, what permission or reviewed exception is being relied on, and whether that use matches the intended campaign. Keep evidence of the decision and an owner who can answer questions. A public business email address or a supplier’s assurance is not a substitute for reviewing the circumstances.

Check how objections and unsubscribes are applied across your email tool and CRM. A contact should not be reintroduced through a later import simply because the systems are disconnected. Agree retention and access arrangements with the responsible team.

Review the message and the follow-up

For recipients you may lawfully contact, explain who is writing, why the content is relevant, and what happens next. Use accurate product claims and a clear way to respond or stop further messages. Test links, sender details, suppression behaviour, and the sales handoff before the campaign goes out.

Do not promise a reply rate based on nationality. Evaluate relevance, useful replies, objections, and qualified conversations using your own campaign evidence. A personalised message still requires an appropriate basis for sending it.

Make launch review concrete

Bring the reviewer the actual audience source, permission records, message, follow-up sequence, tools, and suppression process. A general question about whether cold email is allowed cannot resolve all of those facts. Record the decision and revisit it when the audience or use changes.

For broader planning, read the European market prioritisation guide or get in touch.