133 - Can a non-gated medical journal web site, whose online advertising is restricted to reminder ads and non-pharma ads, offer unrestricted access to a complete digital version of back issues of the journal (Rx advertising would appear as it does in print)?
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The Rx drug advertising on a non-specialized medical journal may appear on a non-gated website if the Rx drug advertising does not go beyond the name/price/quantity restriction relating to consumer advertising of prescription drugs (i.e. Section C.01.004 of the Food & Drug Regulations). Ensure that this is also the case for back-issues unless they will be gated. The appearance of name-only ads in a specialty medical journal (e.g. Journal of Psychiatry, Journal of Urology...) conveys the message that the drugs are for a condition relating to that specialty. Those ads would therefore exceed the aforementioned C.01.004 restrictions. Also note that "reminder ads" can mean different things in different contexts. In the PAAB code for example, a reminder ad would contain the product's indication. A "reminder ad" of this nature should not be accessible to the general public as this would also exceed the aforementioned C.01.004 restrictions (regardless of the type of journal). This is different from the way in which the term "reminder ad" is used in a DTC context (i.e. name/price/quantity).
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@jennifer-carroll Hi Jennifer, does a reminder ad with indication statement running in a specialty pub require anything more if the drug has a black box warning? Only brand colours and logo would be used, no creative/visuals.
