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May 13, 2010
A brave Canadian pharmaceutical company has taken the plunge and is giving FaceBook direct-to-consumer (DTC) advertising a try. King Pharmaceuticals has been promoting its EpiPen.ca website via the following English and French FaceBook ads: The call-to-action is to take the allergy risk test, but it appears as though the main objective of the site itself is to introduce the new EpiPen and EpiPen Jr (0.3 and 0.15 mg epinephrine) Auto-injectors ("EpiPen") to Canadian consumers and healthcare professionals. Both the FaceBook ads and the site are DTC advertising. Although King Pharmaceuticals launched the new EpiPen and EpiPen Jr Auto-Injectors on April 14 2010, I first noticed the FaceBook ad on Monday May 10th 2010. Of course, it is possible that the ad was launched sooner and that it just came to my attention later. Can a prescription Rx brand copy this social media model? EpiPen falls under “ethical pharmaceuticals” in the regulatory system. However, it is not a schedule F product (prescription required for sale). Therefore, section c01.044 of Canada's Food and Drug Regulations Act (which limits pharmaceutical DTC advertising to only product name, price, quantity) does not apply. To promote a prescription product (Schedule F) in a FaceBook ad (DTC), only the product name, price and quantity would be allowable because it is a public direct-to-consumer placement. Since the PAAB approves campaigns as a whole, this would also apply to any website that the FaceBook ad would link to. For more information about Canadian regulatory requirements for prescription products promoted in social media, see Highlights from “Social Media Marketing in Pharma: What Works in Canada" or contact Patrick Massad at the PAAB. If you are interested in learning more about Canadian regulatory guidelines for other types of healthcare products, you might like this article. Is this the first Canadian pharma ad on FaceBook? As far as the ads that I have seen on my personal FaceBook profile, this is the first one that I have seen from a Canadian pharmaceutical company. There may have been others. I might have missed them, or perhaps I was not part of the target market for the ad. So unless somebody tells me otherwise, I do believe that this is the very first branded FaceBook ad by a Canadian pharmaceutical company. In fact, I have not seen an unbranded FaceBook ad by any Canadian pharma companies. I you know of others, then please share in the comments section. Is the FaceBook ad driving traffic to the EpiPen.ca website? Since the EpiPen FaceBook ad seems to have the objective of driving unique visitor traffic to the EpiPen.ca website, it is reasonable to track traffic to the site as an ROI measurement. As an outsider, I will use data from Alexa and Compete. The following data and snapshot were taken on May 12 2010:
- Alexa traffic rank as of May 12 2010 is 1,562,812
- Alexa traffic rank in Canada is 27,244.
- 1,177 monthly unique visitors to the website in February 2010.
January 20, 2010
As a pharmaceutical marketer, you need to be creative and innovative to achieve your brand's strategic and financial objectives, but you must do so while staying within the regulatory guidelines. In Canada, there are several sets of regulatory guidelines and codes that relate to Canadian pharma / healthcare advertising and promotion. How do you know which ones to follow for which circumstances? Patrick Massad, the Chief Review Officer at the PAAB, presented an algorithm at the “Social Media Marketing in Pharma: What Works in Canada” workshop, which is meant to help identify which set of guidelines to follow in certain circumstances. A modified version is found below. When in doubt, contact the various regulatory bodies and explain your specific situation to determine which organization is responsible for clearing your advertising / promotional collaterals and campaigns. Note that the Health Canada Food & Drugs Act is the basis for the policies, guidelines, and regulations on drug advertising. Regulatory bodies enforce these.
|TYPE OF PRODUCT|
Rx and Schedule D product
Non-prescription / Natural health product
|Promoting to Healthcare Professionals||Pharmaceutical Advertising Advisory Board (PAAB)||Pharmaceutical Advertising Advisory Board (PAAB)|
|Promoting to Patients (have a prescription for the product)||Pharmaceutical Advertising Advisory Board (PAAB)||Pharmaceutical Advertising Advisory Board (PAAB)|
|Pharmaceutical Advertising Advisory Board (PAAB) OR Advertising Standards Canada (ASC) can provide an opinion on behalf of Health Canada||Advertising Standards Canada (ASC) OR MIJO (Formerly BCA)|
For those who are curious, the following is a list of promotional guidelines for some other countries; Australia: Medicines Australia Medical Technology Association of Australia Brazil: Agência Nacional de Vigilância Sanitária (Anvisa) / (Brazilian Health Surveillance Agency). Promotional guidelines in Portuguese only. Denmark: Danish Medical Association (LF), Danish Pharmaceutical Association (DA), Danish Association of the Pharmaceutical Industry (Lif), Danish Generic Medicines Industry Association (IGL), Parallel Importers of Pharmaceuticals (PI) Europe: European Federation of Pharmaceutical Industries and Associations (EFPIA) EFPIA Code on the promotion of prescription only medicines to, and interactions with, healthcare professionals EFPIA Code of practice on relationships between the pharmaceutical industry and patient organisations France: Les Entreprises du Médicament (LEEM) United Kingdom: Association of the British Pharmaceutical Industry (ABPI) United States of America: Pharmaceutical Research and Manufacturers of America (PhRMA) Division of Drug Marketing, Advertising, and Communications (DDMAC) Advanced Medical Technology Association Note that I am not a pharmaceutical regulatory expert. I am providing these resources as a service to my blog's readers. If you have specific regulatory questions, please contact the appropriate organization. Stay in touch, Natalie Connect with me on the following networks: FaceBook, Twitter, LinkedIn
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