130 - For a DTC help-seeking message for a preventative product (e.g. vaccine), can the name of the manufacturer appear on the ad?
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In the case of DTC messaging for preventative, non-prescription products (e.g. vaccine), the name of manufacturer may appear on the ad. In fact, section A.01.067 allows certain non-Rx drugs and NHPs to make prevention claims for schedule A diseases in advertising directed toward consumers. It may even be branded for the product; in such a case, the message will be considered to be promotional and advertising regulations would apply (e.g. please refer to the Health Canada Interim Guidance "Fair Balance in Direct to Consumer Advertising of Vaccines").Please note that this is not be confused with DTC messaging for prescription drugs or treatment of schedule A diseases. For these, the Health Canada guidance document "Distinction Between Advertising and Other Activities" applies and there should be no mention of the product or corporate name on the help-seeking message.Please call the PAAB office if you have any questions about this.
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@jennifer-carroll Hi! In response to the latest Guidance on distinction between
advertising and other activities for health products update (Aug 2023). They have now mentioned that 'Declaration of sponsorship of such materials, by name or logo, is required and does not in itself render the material promotional.' under Medical condition and treatment awareness materials.Has the PAAB code been updated to reflect this change? Do we now have to include manufacturer name on unbranded disease awareness pieces?
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The Health Canada Distinction between advertising and other activities document is separate from the PAAB code which is for advertising directed to health care professionals and patients as per Code Section 1.3B. Code section 7.5 provides guidance for editorial advertising/promotion systems (APS) and states that it should be clearly identified as advertising to distinguish from other editorial presentations; hence, this requires that the manufacturer’s name be included in unbranded editorial APS. Note that code section 1.4K.A. also provides direction for digital media for various content including unbranded information and indicates that the pharmaceutical company sponsor should be clearly stated in the advertising.
