Direct to Consumer Advertising

Question 1

What is the definition of health product advertising?

Answer 1

Any representation (TV, radio, internet, print, etc.) for thr purpose of promoting directly or indirectly the sale or distribution of any health product

Question 2

Are all public messaging around drug therapies advertising?

Answer 2

Not always, some may be considered non-promotional

Ex. press releases, consumer brochures, help-seeking announcements, scientific exhibits, and journal articles

Question 3

What regulatory boards oversee advertising of drugs?

Answer 3

PAAB (Pharmaceutical Advertising Advisory Board) & Ad Standards are two agencies that review and preclear advertising material in order to help the pharmaceutical industry ensure compliance with the regulatory provisions

Question 4

Can drug manufacturers target children in their advertising?

Answer 4

No, advertising must be directy explicity toward adults (even if the product is indicated for children)

Question 5

What is the PAAB?

Answer 5

The Pharmaceuical Advertising Advisory Board (PAAB) is a self-regulated, independent, not-for-profit review agency made up of multi-stakeholder industry experts

They do not make the rules for advertising, but ensure compliance with federal legislative regulation

Question 6

What do all of the PAAB board members have in common?

Answer 6

They are all groups that are involved in the development and distribution of drugs

Question 7

What is IMC?

Answer 7

Innovative Medicines Canada (IMC) is the national association representing Canada’s innovative pharmaceutical industry

They can meet with HCPs and other government employees for the purpose of commercializing prescription medicines (need to follow IMC Code of Ethics)

Question 8

What is Ad Standards?

Answer 8

Ad Standards is the national not-for-profit advertising self-regulatory body (not just for prescription medications)

Ad Standards does not create regulations, but instead enforces the Canadian Code of Advertisng Standards

Question 9

Can a drug be marketed without a notice of compliance (NOC) number?

Answer 9

No, promotion of a drug prior to market is not permitted

But marketing for drugs in the USA can leak into Canada

Question 10

What are the types of advertising for drugs?

Answer 10

• Reminder branded messages (include name of brand, restricted to the name, price, and quantity)
• Help seeking announcements (ask patients among the general public having a particular medical disorder or symptoms to see a HCP for treatment options, no specific drug is identified and neither is drug manufacturer name included)
• Consumer brochures (content is disease-related, rather than product related. Various treatment options discuseed and no emphasis on the merits of a single product)
• 1-800 telephone numbers/websites (content is disease related, rather than product related. Various treatment options discuseed and no emphasis on the merits of a single product)
• Clinical trial recruitment (intent is clear regarding clinical trial recruitment, includes patient profile required, includes contact info for more details about the study, no reference to drug manufacturer or name of drug)

Question 11

How is marketing for vaccines different compared to other drugs?

Answer 11

Promotion of vaccine use is seen as a public health message and not advertising. Vaccines are in a different drug schedule compared to drugs, which further separates them from the advertising rules for other drugs.

Advertisements for vaccines still need to be accurate, truthful, objective, and provide balanced information (risks vs. benefits)