Unauthorized Use of Content on this Site: 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 correspondence—are specifically intended to assist individuals navigating the PAAB preclearance system. Repurposing or reproducing this content, or using it for model training or any related purposes, is strictly prohibited without the express prior written consent of PAAB. This includes, but is not limited to, the use of such materials in automated systems, machine learning models, or artificial intelligence applications.
DTC - mention of a therapeutic class that is not of the sponsor
-
A client wants to develop videos to be used on social media. The videos will mention the disease state, but not the product itself. There will be no branding. There will however, be mention of a therapeutic class of products that is common for these patients to take in large quantities. This therapeutic class is not the sponsor's product class, but since the other therapeutic class is so common for these patients, it comes up in comments. Is this allowable?
-
Afternoon @natbourre
Consumer regulations are in effect regardless of whether the company has a product in the specific class, or not. The copy should be reviewed and approved against the Distinction Between Advertising and Other Activities document. Mentioning a condition and one class of treatment would not meet the consumer brochure restrictions and therefore is unlikely to be considered acceptable. Additionally, the sponsor is still responsible for the acceptability of all comments, shares and comments on shares associated with social media. They will be expected to monitor and moderate to ensure compliance with consumer regulations.