Hi PAAB, If a pharma company who markets a vaccine sponsors a 3rd party to commission the the writing of an independently written educational article on adult vaccines, in which all treatments are discussed and this vendor distributes this article to consumers through their channels, is this considered promotional? Would the article require PAAB review? The Pharma company would not review the article.
The evaluation of whether this falls under advertising should be based on the Health Canada "Distinction Between Advertising and Other Activities" document. There is a probability that by commissioning the production of the review, this would be perceived as advertising and therefore subject to the code, especially if the final report favors the sponsors product. The question also mentions "consumers" and therefore, the consumer regulations would have to be taken into consideration (cannot exceed name, price, quantity).
We would suggest submitting for an opinion to gather a more thorough evaluation of the proposed project.