The US must model its anti-spam laws upon those in Europe if it is to effectively crack down on unsolicited email, the All Party Internet Group (APIG) has warned.

The parliamentary anti-spam group is sending a group of its members to Washington to persuade the US congress that unless there are similar global laws to outlaw spam, the problem could get worse.

APIG believes that the EU solution offers better protection than many of the bills currently in front of congress.

"We are not saying we have the right solution but it's in everyone's interest to find a solution," said APIG treasurer, Brian White MP.

The group is concerned that the US might adopt an opt-out measure. This would be at odds with the EU directive on Privacy and Electronic Communications, which will introduce the opt-in principle to EU member states.

"The US should adopt the opt-in line we have here in the EU, and this is the single most important measure in the report," said Richard Allen MP, APIG's joint-vice chairman.

He warned that if the US, which is currently considering a number of anti-spam bills, adopts one at odds with the EU, it could "potentially make matters worse, which is why we are going to Washington to beat the drum".

Brian White feared differing laws would be leapt upon by spammers, who would use dissension to wriggle off the hook. "We want to make legislation complementary so spammers can't play countries off against each other."

Also in its report on spam, APIG warned that the UK Information Commission, which has to police the EU anti-spam laws, is under-resourced. If policing spam is to be effective, it advised, government will have to give the commission stronger powers to deal with spammers.

And the group criticised the Department of Trade and Industry for a loophole in the planned enforcing of the directive, which does not penalise spammers sending their junk mail to businesses.

The DTI has made "a very serious mistake in not prohibiting unsolicited business-to-business email", said APIG, calling on the department to reverse this decision.