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.
164 - I intend to send out a PAAB-approved promotional piece to physicians in a direct mail campaign for an OTC product. I was also considering including a product coupon. The coupon will display the brand name, package shot and discount amount. There will be no claims. Should the coupon be submitted to PAAB, given that it will be distributed in the same envelope as a promotional piece?
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In this scenario, the coupon piece should be precleared if claims are visible on the package shot visual within the APS. Otherwise it is exempt from preclearance. Either way, please inform us of the linkage to the PAAB approved piece. We would need to assess the appropriateness of the linkage. For example, the coupon piece should not accompany an editorial (unbranded APS) as this would inherently brand that piece.
