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  3. FYI post-approval change/preclearance exemption/what requires review/PAAB scope
  4. Corporate messages
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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.

Corporate messages

Scheduled Pinned Locked Moved FYI post-approval change/preclearance exemption/what requires review/PAAB scope
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  • N Offline
    N Offline
    nhem
    wrote on last edited by
    #1

    Hi, I would like to know what is the definition of a corporate message under section 1.5 of the PAAB code.

    Section 1.5 mentions that "Corporate Messages that do not Contain Product Information or Product Lists" would not be subject to pre-clearance. However, section 7.4 states that "[Corporate advertising /promotion systems] may be used at any time at the discretion of the advertiser but must be submitted for PAAB preclearance prior to publication." The same section says that "Product information does not have to accompany corporate advertising," which suggests that even corporate messages without product information must be submitted for pre-clearance. This seems to contradict the section 1.5.

    So my question is, what is the definition of a corporate message under section 1.5 vs. section 7.4? Thank you.

    Jennifer CarrollJ 1 Reply Last reply
    1
    • N nhem

      Hi, I would like to know what is the definition of a corporate message under section 1.5 of the PAAB code.

      Section 1.5 mentions that "Corporate Messages that do not Contain Product Information or Product Lists" would not be subject to pre-clearance. However, section 7.4 states that "[Corporate advertising /promotion systems] may be used at any time at the discretion of the advertiser but must be submitted for PAAB preclearance prior to publication." The same section says that "Product information does not have to accompany corporate advertising," which suggests that even corporate messages without product information must be submitted for pre-clearance. This seems to contradict the section 1.5.

      So my question is, what is the definition of a corporate message under section 1.5 vs. section 7.4? Thank you.

      Jennifer CarrollJ Offline
      Jennifer CarrollJ Offline
      Jennifer Carroll
      wrote on last edited by Jennifer Carroll
      #2

      Hi @nhem

      The entirety of 7.4 states:

      Corporate Advertising / Promotion Systems (APS) These are designed to create and maintain a favorable image of a company, its products and its services. See Section 1.5: Materials Not Subject to PAAB Review. These systems may be used at any time at the discretion of the advertiser but must be submitted for PAAB preclearance prior to publication. They must not contain therapeutic or other claims of product merit or status. They may contain:

      1. A general statement about the pharmaceutical company, its products and its service(s) and policies.

      2. A partial or complete list or illustration of products manufactured and/ or distributed by the company, along with their respective therapeutic or pharmacologic classifications

      3. Product information does not have to accompany corporate advertising.

      This therefore conveys that corporate messages which do not contain product information or product lists (direct or indirect) are exempt per 1.5. The remaining scope of corporate advertising is subject to review per 7.4. As an example:

      “Company X employs 2000 Canadians” is a corporate message that does not speak to products or product lists. This message (as a stand-alone message), would be considered exempt.

      “Company X is the proud manufacture of Product Y” is a corporate message that contains product information. This APS would be subject to review.

      “Company X is dedicated to research in the treatment of condition Y” would be subject to preclearance as it alludes to products when it states “treatment”.

      The copy “Product information does not have to accompany corporate advertising” refers to the fact that corporate messages may make mention of products, but do not require the fair balance or TMA link if they meet the spirit of a corporate message and are not brand promotions.

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