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  4. 528 - On a company website, would we be able to show a picture of a drug along with name, price, quantity and product monograph? Would we be able to also link this drug page to a medical device that it is intended to be used with?

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528 - On a company website, would we be able to show a picture of a drug along with name, price, quantity and product monograph? Would we be able to also link this drug page to a medical device that it is intended to be used with?

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  • Jennifer CarrollJ Offline
    Jennifer CarrollJ Offline
    Jennifer Carroll
    wrote on last edited by
    #1

    Quite a bit of information is missing here. I'm going to take a stab in the dark and assume you are talking about a prescription product and this website is not gated. Although a name/price/qty advertisement is likely fine in an environment accessible by consumers, adding the product monograph (or a link to it) would appear to contravene section C.01.044 of the Food and Drug Regulations. The reason being that this would link the product ad to the product's therapeutic use.With regards to the link to the medical device, that would depend on whether the device alludes to the therapeutic use. If it does, then you cannot do that either.Don't think of it in terms of "I can link A, B and C to a consumer reminder ad but I can't link X, Y or Z". That just get's confusing and you'll feel like you are contradicting yourself each time the context changes. Instead, think of it as "I need to make sure that the advertisement AND its environment/context do not enable the consumer to readily infer the therapeutic use of my prescription product".

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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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