Hello @andrewleeson

The added clarification copy “however, linking a name-only banner ad to the TMA renders it non-exempt from preclearance as this constitutes a link to therapeutic messages” was added so as to help avoid the misinterpretation that just because there “should not be an issue linking such banner” meant that the banner remained exempt. The activity of linking the banner to a therapeutic message renders it no longer exempt. We did not believe that was clear with the initial response.

We will remove 517 to help reduce confusion. Please consider the response in 330 to be accurate: “A piece containing only the message "Drug X is coming soon" with absolutely no other message (implied or stated) within the piece AND absolutely no link to therapeutic or promotional messages is exempt. Note that the manufacturer is responsible for ensuring that this message is employed only AFTER the product has been approved by Health Canada. It is prohibited to advertise a drug product prior to Health Canada approval.”

Great question @gbrl88

Question 654 is a great primer for this question.

The same response applies to a HCP audience. All links must be assessed for acceptability within the context of the brand. Note that a key point for considering the link, is that the site is an authoritative independent third party site. A direct link to off-label content would not be acceptable even in the presence of a second gating mechanism.