Branded DTC and Branded HCP

[GMC]

We are looking at a branded DTC ad that would be reviewed by ASC. It would have a headline that was compliant. Could this same headline be used in a branded HCP APS?

[Jennifer Carroll]

Hi @tmcm

The use of a headline in a DTC campaign does not, in and of itself, prohibit its use in an HCP ad. The regulations for DTC advertising and HCP advertising vary and may impact the acceptability of copy depending on the context and audience. For clarity and completeness, we suggest being transparent about the use in the DTC campaign when submitting the HCP campaign for review.