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K

kshulist

@kshulist
Agency
PAAB Notice
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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Recent Best Controversial

  • How does PAAB define the start of marketing for "new" claims?
    K kshulist

    Hi there!

    I know that messages of "new" (or "introducing") are limited to one year post-marketing. I am wondering how PAAB defines the date that is considered the start of "marketing"?

    For example, Drug X gets NOC on Oct. 13, 2023, however, the first official marketing piece is only released to HCPs (e.g., a "Now Available" email) on Mar. 4, 2024. Does that mean that "new" can be used until Mar. 4, 2025 (since the marketing didn't officially start until Mar. 4 2024)? Or would "new" only be allowed to be used until Oct. 13, 2024 (as per the NOC date)?

    If it is based on the date the first marketing material is released (e.g., Mar. 4, 2024), does PAAB required some kind of confirmation letter from the company supporting that specific date as the start of marketing? (e.g., perhaps if a material was submitted after Oct. 13, 2024 but still included a "new" message)

    Thank you so much for your help!

    Claims & Support/References for Claims
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