Submission of materials for informal market research
My understanding is that market research materials are not subject to PAAB review. Is this true for market research that is done informally, or is there formal guidance around what is considered market research?
Jennifer Carroll last edited by
Let’s begin by setting a common understanding of what is market research (and what isn’t market research).
Market research has the sole purpose of pointing out and defining marketing opportunities and issues; generating, refining, and evaluating marketing programs; monitoring marketing performance; identifying patient and prescriber needs and improving understanding of the marketing process. The planning, implementation, evaluation, and utilization of market research should reflect that sole purpose. The activity is not considered market research if the purpose includes promotion of a health product (or the features/properties of that product). The content, its context and tone should reflect these facts as should the type and number of participants (and the nature of the agreement/contract where applicable). We invite you to refer to the “General Principles” section of the Distinction Document to determine whether the activity is potentially subject to advertising regulations (and consequently subject to PAAB preclearance if targeting HCPs). The IMC Code of Ethical Practices is an additional resource for standards/factors pertaining broadly to market research and for some specific examples of market research.
True market research is generally not considered subject to advertising regulations. And consequently, the PAAB Code standards and preclearance are not applicable. However, please note that some activities that are believed to be market research are actually promotional in nature. If there is any doubt, you are welcome to use the PAAB advisory opinion service to confirm whether any particular activity is indeed exempt from advertising regulations (see our fee schedule for more information).
Please note that communication of market research findings in advertising is subject to preclearance.