34 - Heatlh Canada has issued a policy entitled "Distinction Between Advertising and Other Activities" which states that " No one factor in itself will determine whether or not a particular message is advertising. Each message must be evaluated on its own merit and other factors may apply." An earlier response in this forum suggested that if it was a single sponsored publication, it was quite likely to be advertising if it dealt with therapeutics (you used the term "rarely" to describe the incidence with which you have seen non-promotional single-sponsored 3rd Party pieces.) Here's my question - if it is a single sponsored publication and mentions both the sponsor's and the competitor's products, giving them more coverage than "name, price, quantity", but not creating an impression in the reader's mind of bias, is it advertising? It seems obvious that one...
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continued ... person's perception of information distribution "...serves to promote the sale of that product either directly or indirectly" (s11.1) may differ from anothers. And how does pharma or their agents know when when the line from "other activity" to "advertising", based on Health Canada's policy, has been crossed, short of a violation or submitting everything for a review?
Response: Please see section 11.1 in the PAAB Code. It gives the PAAB working definition of advertising. That is what we use for the purpose of the PAAB Code. The Health Canada "Distinction ..." Document explains how Health Canada interprets what is "advertising". A company stays in business by selling its products. It invests money into communications about its products to enhance their sale. That is advertising. If the information is created independently of the company it is usually not advertising. Companies want an ROI on money invested into communications projects. I have not seen many examples of communications created by pharma companies about their products that were not intended to sell their products.
