TCPA and 10DLC texting rules for car shipping brokers
A car shipping broker may call or text a customer who gave consent, must stop within ten business days after a STOP or other opt-out, and may make sales calls and texts only between 8 a.m. and 9 p.m. in the customer's local time, with some states stricter. Business texts also have to go out from numbers registered to an A2P 10DLC campaign, or the mobile carriers may not deliver them.
This is a plain summary of public rules with links to each source, and it is not legal advice, so have a lawyer who handles TCPA cases check your forms and scripts.
Two sets of rules touch every text your desk sends. The Telephone Consumer Protection Act and the FCC's rules in 47 CFR 64.1200 cover consent, opt-outs, calling hours and do-not-call lists. The mobile carriers and the wireless industry's CTIA Messaging Principles and Best Practices decide whether a business text gets delivered at all.
Who can a car shipping broker call or text?
Start with what the customer did. Under the FCC rule, a call to a cell phone made with an autodialer or a prerecorded voice needs the person's prior express consent. The FCC's opt-out rule speaks of "calls or text messages" made under these consent rules, so plan on texts needing the same consent as calls.
When the call or text is telemarketing, meaning it encourages someone to buy, and it uses an autodialer or a prerecorded voice, the rule asks for prior express written consent. That is a signed agreement naming the phone number, and the signature can be electronic if federal or state law accepts it. The agreement has to tell the person that signing is not a condition of buying.
CTIA sorts business texts into three kinds, each with its own level of consent:
- Conversational. The customer texts you first and you answer. CTIA expects no further permission.
- Informational. The customer gives you their number and asks to be contacted, for example on a quote form. CTIA expects express consent for that purpose.
- Promotional. A sales or marketing message, such as a discount for booking this week. CTIA expects express written consent, such as a checked box on a form.
A quote request from a lead seller or from your own website is a customer asking to be contacted. What they agreed to depends on the words next to the submit button, so get that wording from every lead source and keep it with the lead.
Sales calls also run into the national Do Not Call Registry. The FCC rule bars telephone solicitations to registered numbers, and it applies those protections to texts sent to cell phones. A call to someone you have an established business relationship with is not a telephone solicitation under the rule. That relationship covers a person who asked about your service within the last three months or bought from you within the last 18 months, and it ends when they ask you to stop.
How fast do you have to honor STOP?
Under the rule in force today, a customer can revoke consent by any reasonable method. A reply of "stop," "quit," "end," "revoke," "opt out," "cancel" or "unsubscribe" always counts, and so does any other reply a reasonable person would read as a request to stop. You have ten business days at most to honor it, and you may not name one method as the only way to opt out.
That changes on November 25, 2026. In an order published on October 26, 2026, the FCC amended the rule so a sender may name one opt-out method as the only one it processes, such as a reply with one of those seven words, as long as each text discloses it. A line like "Reply STOP to opt out" is enough disclosure, but you still have to accept all seven words. The ten-business-day limit stays.
After an opt-out you may send one text that confirms it, with no sales content in it. The rule presumes a confirmation sent within five minutes is fine.
Sales calls carry a second list. A business that makes telemarketing calls needs a written do-not-call policy and trained staff. It has to record a request at the moment it is made, honor it within ten business days and keep it for five years.
What hours can you call and text car shipping customers?
The federal rule bars telephone solicitations before 8 a.m. or after 9 p.m., in local time at the called party's location, and the FCC applies it to sales texts sent to cell phones. Car shipping makes this easy to get wrong. The customer may live in a different time zone from your desk and from the pickup city, and an area code says nothing about where a cell phone is today.
Some states are stricter. Florida's telemarketing law bars commercial telephone solicitation calls before 8 a.m. or after 8 p.m. in the called person's time zone, and more than three such calls to one person in 24 hours on the same subject. Florida's telephone solicitation statute also gives a sender 15 days to stop text solicitations after the person replies STOP. Check the law of each state your customers live in before you set send times.
Autodialers, prerecorded voicemail and the TCPA
The FCC rule defines an autodialer as equipment that can store or produce numbers to be called with a random or sequential number generator, and dial them. Whether your dialer fits that definition is a question for your lawyer. A prerecorded voice is covered whatever dials the call.
A prerecorded message has to name the business at the start, using the name it is registered under with the state, and give a phone number during or after the message. A prerecorded sales message also needs a key-press or voice opt-out within two seconds of that identification. A recorded voicemail drop plays a recorded message, so check what consent you hold before you drop one on a lead.
What is A2P 10DLC registration?
A2P means application-to-person, texts sent from a business system instead of someone's own phone. 10DLC means a 10-digit long code, an ordinary local phone number. The Campaign Registry (TCR) describes 10DLC as a channel where brands and their messaging providers are verified before they may send.
TCR does not take registrations from businesses directly. Your texting provider files for you, in two parts:
- Brand. Your business. RingCentral's registration FAQ says the brand usually matches your legal company name and that you need a federal business ID such as an EIN.
- Campaign. How you use your numbers, with use cases and sample messages. Every number that sends texts has to be linked to a campaign, and one number can sit on only one campaign.
Expect fees. RingCentral lists a brand registration fee, an optional brand vetting fee, campaign vetting fees and monthly campaign fees, all passed through on your invoice, with a three-month minimum. It suggests a low-volume campaign for accounts that send fewer than 6,000 messages a day.
What do mobile carriers block?
T-Mobile counts messages from transportation and delivery services as non-consumer messages, and those must be part of an approved campaign to reach its customers. Every sender of approved 10DLC traffic must register before its campaign messages are approved for delivery. Business texts sent over unregistered "gray routes" risk being delayed or never delivered, and T-Mobile's email-to-text gateway prohibits business messaging. On RingCentral, a number that is not linked to a campaign cannot send texts at all.
Content gets reviewed too. T-Mobile's Code of Conduct lists content that business campaigns may not send, and CTIA asks senders not to text opt-in lists that were rented, sold or shared. Keep the sample messages in your campaign close to the texts your desk sends.
What records should a broker desk keep?
CTIA lists the consent details to keep: when consent was given, where (a web form, a text, a paper form), the wording the customer saw, the campaign it was for, the IP address, the phone number and who consented. Keep opt-outs with the same care, because they decide what may never go out again.
For sales calls, the FCC rule gives you a defense when a call reaches a registered number by mistake if you can show, among other things, written procedures, staff training, your own list of numbers not to call, and a copy of the national registry no more than 31 days old.
TCPA and 10DLC checklist for a broker desk
| Check | Rule behind it |
|---|---|
| Save the consent wording, time and source for every lead | CTIA consent records; written consent for marketing by autodialer or prerecorded voice |
| Register your brand and a campaign with your texting provider before the first text | TCR, T-Mobile and RingCentral registration rules |
| Link every sending number to the campaign | An unlinked RingCentral number cannot send texts |
| Put "Reply STOP to opt out" in automated texts | CTIA opt-out wording; required disclosure if you make reply words your only opt-out method after November 25, 2026 |
| Block every opted-out number in every tool your team texts from | Ten business days at most under the FCC rule |
| Send at most one confirmation after a STOP, with no sales content | 47 CFR 64.1200(a)(12) |
| Keep sales calls and texts between 8 a.m. and 9 p.m. customer time, and 8 p.m. for Florida calls | 47 CFR 64.1200(c)(1); Fla. Stat. 501.616(6) |
| Write a do-not-call policy and train every salesperson on it | 47 CFR 64.1200(d) |
| Check sales call lists against a copy of the national registry no more than 31 days old | 47 CFR 64.1200(c)(2) |
| Keep do-not-call requests for five years | 47 CFR 64.1200(d)(6) |
| Check consent before any autodialed call or recorded voicemail | 47 CFR 64.1200(a) and (b) |
Check your last 20 texted leads
Pull the last 20 leads your desk texted. For each one, find the consent wording, check the hour the first text went out in the customer's time zone, and confirm that any STOP reply blocked the number everywhere your team texts from. Then see how Leader CRM's automated follow-ups handle STOP numbers and send times, or book a live demo with Brian.
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See Leader CRM on your own leads
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