Seeking some clarification on the response to Question #273. Can you confirm that the answer « It may be exempt if all the treatments are balanced » applies only if the piece in question is consumer-directed? We're assuming that HCP-directed exempt material (s6.6) can never mention treatments (balanced or not), otherwise it would be considered Editorial (s7.5).

Please note that in Question #273 the copy “it may be exempt if all the treatments are balanced” speaks to the references being used to support the piece, not the content within the piece. If a drug manufacturer is generating a piece directed to healthcare professionals, which discusses drug products, PAAB preclearance is required regardless of the degree of balance.


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