What are the rules regarding using similar graphic symbols for branded PAAB approved promotional pieces addressed to HCPs and branded DTC materials for the same OTC product. Is it acceptable that they have the same graphic elements such as icons to illustrate the approved claims/indications?

The link created by using the same visuals (including but not limited to graphics, images, colours and even fonts), is not necessarily problematic, as the content in both cases is branded and as the consumer would not be privy to the HCP pieces. Keep in mind however, that the DTC pieces would be reviewed based on consumer regulations, while the HCP piece would be reviewed based on the PAAB code. This may result in some images which were acceptable for HCP’s, not being acceptable for consumers and vice versa.


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