The pharmaceutical industry's use of digital media in advertising

In the new revised guidance the paragraph on the extent of the concept of advertising has been updated on the basis of the Danish Medicines Agency's new guidance on the Promotion Code, and the guidance now also includes a specific paragraph on influencers from which it emerges, among other things, that the Promotion Code's ban on using persons who have a special reputation in advertising for medicinal products to the public, see Article 10(1)(7), may now also according to the Danish Medicines Agency's guidance on the Promotion Code comprise persons whose reputation is based on personal characteristic. In that connection it appears that the concept of "reputation" also comprises celebrity that is not related to medicinal products, health, etc, nor special status associated with a specific profession, including influencers.

In addition the paragraph on the use of video and podcasts has been updated in terms of the placing of compulsory text. 
 
The list of annexes has also been extended by the addition of the new joint note for guidance regarding social media and digital channels from IFPMA and EFPIA. Relevant references to the new joint note have now generally been included in ENLI's guidance. 
 
Read ENLI's new guidance