The responses, guidance, and advisories provided by the Pharmaceutical Advertising Advisory Board (PAAB),
including but not limited to those available through the PAAB Forum, the PAAB website, and any PAAB
correspondences, are specifically intended to assist individuals navigating the PAAB preclearance system.
Repurposing or reproducing this content without written consent from the PAAB Commissioner is strictly
prohibited. This prohibition includes, but is not limited to, use in machine learning or AI models.
738 - Would it be acceptable to use an image in a patient support material (PSP) if the same image is being used in healthcare professional branded material? The product only has one indication and PSP material would specifically be distributed to patients prescribed the product for the approved indication.
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The fact that an image has been used in HCP branded advertising does not make it ineligible for use in patient information. Keep in mind however, that unlike HCP advertising, patient information cannot be promotional. So a key distinction is whether or not the image itself is promotional, in which case it would not be acceptable for a patient tool. This same concept applies even if the PSP is not overtly branded. In other words, by using imagery from a branded piece, the PSP becomes branded and as such should meet the restrictions of a branded patient piece.
