For two months, Health Canada will open a public consultation on its guidance about promotional ads for health products, such as medical devices and drugs. They want to protect the public by helping to distinguish a promotional message from educational content, and so they aim to update their guidance to fit society today.
The Importance of Advertising Policies
Health Canada wants the public to understand the difference between promotional content that advertises the drugs, versus educational content such as reports or scientific exchanges. They define advertisement as “any representation by any means whatever for the purpose of promoting directly or indirectly the sale or disposal of any food, drug, cosmetic or device.” It’s important to clarify the difference between promotional and non-promotional content, because companies are not allowed to promote their drugs before they are authorized to do so, and promotions have limitations. For instance, prescription drug promotion is limited to its name, price, and quantity, and cannot claim to prevent, treat, or cure Schedule A diseases (such as cancer or obesity.) These policies prevent false advertisement of drugs and medical products, and ensures the public’s safety.
Why The Change
They claim that the reason for this move is to accommodate modern “advertising context, practices, and trends.” A change in time comes with a change in ideas, and so they want to modernize their policies in order to fit into society today. They hope to hear from a diverse group of professionals, from health product manufacturers to advocacy groups, regarding this matter. The consultation period will end on September 3, 2019. It’s current guidance was written in 1996, and revised in 2005. This new draft will replace the old guidance. Health Canada recognizes certain non-government agencies to review promotional ads before they are made public.
To determine if a material is promotional material or not, they consider these:
- The context of the message
- Who primary and secondary audience is
- Who delivers the message
- Who sponsors the message, and how
- Influence the drug manufacturer has on the message
- The content of the message
- The frequency in which the message is delivered
Of course, determining whether a message is a promotional ad is a case-by-case basis. In order to understand what Health Canada looks for, they provided various examples with different promotional materials which can be found on their website here. Medical device regulations