On May 4, 2010, the FDA posted a warning letter which had been sent to Novartis regarding two unbranded websites. This warning letter is unique because it tackles an interesting pharmaceutical situation: unbranded marketing for a brand with no competition. The warning letter criticizes everything from website copy and design to linking strategy and domain registration. While the situation is unique, the implications can be applied across online content. Unbranded and branded content must remain separate, and where no competition exists, even greater standards must be used to maintain separation. Regarding the FDA, this letter, and a recent increase in letters for digital elements, suggest that digital tactics are being held to stricter standards than in the past, but more importantly that the FDA is seriously investigating digital content.
Download important guidelines for marketers to follow when developing pharmaceutical emails: RTCRM Perspectives Novartis Unbranded Websites FDA Warning Letter 5.10.10
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