In the context of promotional activities, more and more of our customers are Greece Email List about regulatory aspects with regard to the advertising of their health products for the digital or traditional side of their activities. And that’s a good thing! The sanctions and fines practiced in these areas could be seriously penalizing.

The regulation invites the health industry not to boast too commercial manner their services and products and adopt an informative tone remembering to highlight the potential side effects and risks associated with their drugs, medical devices … This point plays in favor of activities like those that we put in place for our customers around their brand, namely to do a health promotion before making a promotion of the drug. Even if it is not a question of putting a particular reference directly to its advantage, the advantage for the manufacturer is to become influential in a therapeutic area, to provide expertise on a disease, to providepatient service … We are now talking about storytelling, blogging, collaborative platforms , educational serious games …

We Are Now Talking About Storytelling

We are addressing this question here by taking our statistical look at the penalties noted across the Atlantic and will discuss the European and French side in a future blog post:

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Mark Senak, associate attorney at Fleishman Hilllard, reviewed breaches of FDA recommendations on his blog, eye for FDA (“Food and Drugs Administration”). More precisely, it carried out a comparison on these infringements noted by the OPDP (“Office for Prescription Drug Promotion” formerly DDMAC or “Division of Drug Marketing, Advertising and Communication”) through the traditional media and those noted on Internet. Mark Senak based himself on the 173 warning letters concerning 675 violations sent by the FDA between 2008 and 2012. Of these, 53% of the violations (or 385 violations) were noted in traditional media, the 47% the remainder (or 290 offenses) come from internet promotion.

Atlantic And Will Discuss The European And French Side

In the context of promotion through traditional media, the first cause of infringement noted by the FDA is the minimization of the risk or the non-presence of risk information. This concerns 33% of the offenses recorded in the traditional media. The second cause of infringement is the exaggeration of the effectiveness of the product through its promotion, this cause concerns 21% of the infringements noted.

The infringements observed within the framework of the promotion of health products on the Internet present a different profile. The proportion of infringements concerning risk minimization or the non-presence of risk information is still the leading cause of infringement but represents 56% of these. In 2009, 14 FDA warning letters concerned advertisements whose risks were mentioned on the page to which the advertisement pointed and not on the advertisement itself. We then spoke of a “one-click rule”which never existed. When these offenses are not counted, the profile of all the offenses identified through internet promotion is much more similar to that of promotion through traditional media.

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