Promotional claims in market research

  • Hi,

    I understand market research is PAAB exempt unless the research will be subsequently used in promotion.

    Just want to clarify - if a market research question contains a product claim, (for example to test the impact of selling messages), do you also have to show fair balance?


  • Good Morning @andreworeilly

    I’ll begin by saying that if you ever wonder whether you need to add the Canadian indication or safety info, you are likely dealing with something that is subject to HCP advertising regulations (and it likely requires PAAB review). Now let’s move onto the underlying question.

    A market research questionnaire must not be designed in a manner that could sway the opinions/attitudes of the HCPs directly or indirectly about the medicines in question. Promotional materials/messages, are inherently intended to shape opinions/attitudes about the medications discussed therein. Consequently, questionnaires are not an appropriate instrument to test promo materials/messages. To be clear, questionnaires are an invaluable way to conduct market research. We are simply questioning their appropriateness for testing promo materials/claims as this would likely appear to be disguised advertising.

    Typically, market research involving promo material testing is done through in-person or virtual meetings adhering to all applicable principles in the Innovative Medicine Canada code. This has many benefits. For example, it:

    • enables the manufacturer to ensure that the HCP does not leave with any material that may be considered promotional

    • provides a mechanism that is conducive to limiting the number of consulted HCPs and the frequency of meetings (i.e., recall that the Distinction document discusses breadth of audience and frequency of use as two of the seven factors that determine whether materials/activities are considered to be subject to advertising regulations)

    • enables a context to be set clearly such that the HCP understands the purpose of and nature of their involvement

    Materials discussed in a legitimate consultation meeting are generally not subject to advertising regulations.

  • Hi @jennifer-carroll!

    Thanks for your reply. Makes total sense. The IMC ethics code for Market Research is quite brief so I appreciate you explaining the practical application. Agree with your conclusion, especially regarding breadth of audience, in this example.