Health Canada is seeking public comment on a draft revision of its regulations regarding the differences between promotional and non-promotional messages about drugs, medical devices and other health products. The proposed revisions would update its guidelines on defining promotional and non-promotional activities, introduced in 1996 and last refreshed in 2005.

The 60-day consultation on the draft guidance, “The Distinction Between Promotional and Non-promotional Messages and Activities for Health Products,” opened July 5 and will close September 3, 2019. It is intended to obtain input on the revised guidance document from all relevant stakeholders, such as industry associations, health product manufacturers, advocacy groups, health care professionals, consumers, the advertising industry, provincial/territorial authorities and others.

Health Canada recognizes that it is important for health product manufacturers to disseminate non-promotional information regarding health products, and for health care professionals and the general public to be able to access such information. The new guidance document is to clarify and outline factors and circumstances that contribute to rendering a message or activity as non-promotional.

The agency notes that since the policy was originally published in 1996, the Canadian advertising landscape has changed considerably. Elements of the policy recognized as in need of updating include the use of the internet and social media in health product advertising. To remain up-to-date on matters of advertising context, practices and trends in developing the draft guidance, Health Canada has been working with two advertising agencies to revise the policy into a more accurate and relevant document.