635 - For APS having only two surfaces (i.e. a double-sided card), can you confirm if market benefit claims can appear on side 1, with the indication appearing on side 2?


  • The two surfaces of a two-sided card are generally considered to be equally prominent surfaces if the card is not appended to anything dictating a “front” or “back” side. In this scenario, the indication would be acceptable on either side, regardless of the positioning of marketing benefit claim. If the card is appended to something or formatted in a way that dictates a front/back designation (i.e. a letter), then the indication is required to appear on the front side if it contains a marketing claim other than those listed in section 1.5 of the PAAB code.