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  3. Exemption for unbranded tool of single product within category

Forum Update: Supporting Community-Led Discussion

The forum was created as a space for shared learning and peer support, and as the community grows, we want to lean more fully into that purpose.

Going forward, PAAB will be taking a more listening-first role in forum discussions. Rather than responding immediately to every question, we’ll be encouraging members to engage with one another, share experiences, and help build collective understanding. PAAB will continue to monitor conversations and will step in to:

  • Correct any misunderstandings
  • Provide guidance when questions remain unanswered after a few days
  • Support discussions where official clarification is needed

Our goal is to foster a collaborative, trusted community where knowledge is shared and strengthened by everyone’s contributions.

Thank you for being part of the conversation.

Exemption for unbranded tool of single product within category

Scheduled Pinned Locked Moved PAAB Q&A
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  • NatBourreN Offline
    NatBourreN Offline
    NatBourre
    wrote on last edited by
    #1

    If there is only one product available on the market within a particular category, would the tool be considered exempt from preclearance if the tool talks about the MOA of the category?

    Natalie Bourré
    Marketing 4 Health Inc.
    Medical Marketing Consultant, Medical Writer
    nat@marketing4health.net

    Jennifer CarrollJ 1 Reply Last reply
    0
    • NatBourreN NatBourre

      If there is only one product available on the market within a particular category, would the tool be considered exempt from preclearance if the tool talks about the MOA of the category?

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

      Hello @natbourre

      An unbranded APS can be considered exempt if it discusses only disease information without any mention of or allusion to drugs/medications/pharmacotherapy. Because the tool would be alluding to medication/pharmacotherapy via discussion of MoA, the APS would not be considered exempt.

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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.
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