319 - I am confused on how Section 6.6vii is different from Consumer Brochures in "The distinction between advertising and other activities". The only differences I can think of is audience (patient vs. consumer), branding (branded vs. unbranded) and treatment discussion (no mention of treatment vs. objective discussion of all available treatments). Am I on the right track? Thanks!
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There are very different regulatory implications to meeting the provisions of any type of non-advertising from the cited Health Canada document versus meeting the provisions of any of the subsection of PAAB code 1.5. The former means the piece is exempt for the advertising regulations in the Food and Drugs Act and the Food and Drug Regulations while the latter simply means that PAAB pre-clearance is not required. You provided some examples of how the requirements differ functionally. The complete Distinction document can be found at: http://www.hc-sc.gc.ca/dhp-mps/advert-publicit/pol/actv_promo_vs_info-eng.php Given the differences, it is essential to generate the piece with the desired endpoint in mind.
