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.
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619 - We’re working on a new product launch and our client is looking to do a PAAB-exempt pull up banner (just product logo and legal text), however, this product has received an NOC/c approval. Are we required to put the NOC/c box on the banner, which disclaimer sea the indication statement?
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Inclusion of the NOC/c box would disqualify the ad from being exempt. Exempt messaging restricted to product name and legal text, would not prompt the requirements for placement of the indication and NOC/c. As a caution, note that if the product logo suggests therapeutic use, this would prompt the requirements for the NOC/c box on the banner and would no longer be exempt from review. PAAB can provide an opinion (see the fee schedule on our website).