466 - What types of claims (if any) are acceptable in email subject lines directed to HCPs?
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You’ve got multiple options when it comes to claims in an email subject line. But first, let’s remind ourselves of the most applicable disclosure requirement. As per PAAB code 2.10 and as described in Q&A # 446, the indication (or at least a statement conveying all boundaries of patient selection) must be presented among or prior to the first set of marketing benefit claims in the APS. This requirement applies regardless of the media. Some of the main strategies used by clients include: Using a claim neutral email title. For example, stating “Read about the safety profile of Drug X inside” as opposed to “Read about Drug X’s excellent safety profile inside” or “Drug X has an excellent safety profile”. The first example would not trigger the s2.10 requirement. Use an overt drug claim but without disclosing the drug name (i.e. a teaser-type statement). For example, stating “Read about a beta blocker which has an excellent safety profile inside” or “Find out what the #1 dispensed beta-blocker is”. Neither of these two examples would trigger the 2.10 requirement. Overt claims listed in PAAB code s1.5.a along with the product name. For example “Drug X is now on formulary” or “Drug X is now available”. This would not trigger the 2.10. This is analogous to the approaches one can use with respect to indication on the first frame of banner ads (Q&A 434).
