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291 - My understanding is that advertising of medical devices such as injectors are not governed by PAAB. However, if a auto-injector can only be used with a specific medication, and one advertises the injector to consumers, is there not a direct association of device & drug? In other words, if the device is so closely connected to the drug, should it not also be subject to PAAB advertising rules, despite the fact that technically, it is a device, not a drug?
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Claims related to Class I, II, III, and IV medical devices as defined in the Medical Device Regulations (MDR) do not fall under the current scope of the PAAB. However, messages relating to drugs fall under the scope. The answer to your question therefore depends on whether the APS messaging relates to an entity which is classified as a drug or as a medical device. I note that your question relates specifically to DTC. Contrary to your question, PAAB assessments for consumer materials are based on the Health Canada guidance documents (not the PAAB code as suggested by "PAAB advertising rules").
