578 - Hi PAAB: We have a new product in our pipeline that is currently undergoing approval process with Health Canada (pre-NOC). We want to do a targeted campaign to HCPs around disease state, We will not be mentioning any clinical data or clinical options. This online piece will be centered around the disease and very general information regarding disease state. Do we need PAAB approval or ASC approval alone is sufficient?
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PAAB approval is required as you’ll be targeting HCPs.
PAAB will review the piece under s7.5 of the PAAB Code of Advertising Acceptance. An important part of our review will be determination of whether the piece alludes to a product. This is important as Promotion of a drug prior to market authorization is not permitted (Section 9(1) of the Act, Section C.08.002 of the Regulations). Note that HCPs have specialized knowledge of the pertinent therapeutic area. It is therefore possible that messaging be deemed not to allude to a product when disseminated to the general public and yet be deemed to allude to a product when targeted to HCPs.
For the consumer tactics, both PAAB and ASC provide an advisory review.
Please see section 2 of the “List of Canadian Advertising Preclearance Agencies” on the Health Canada website for further clarification on preclearance agencies and their roles.
