Professional Documents
Culture Documents
The submission must be produced and lodged with all relevant regulatory bodies to seek
assessment and, eventually, regulatory clearance before a novel medicine or biologic can go
to market.
a) Pre-submission meeting
b) Pre-submission activities
c) Administrative review
f) Decision
There is no advertising or promotion permitted. Unlicensed health care items are prohibited
from being advertised or promoted internationally. “No person shall mark, pack,
manufacture, prepare, trade, or distribute any drug in a manner that is false, misleading, or
deceptive, or that is likely to generate an erroneous impression regarding its composition,
merit, or safety,” says Section 9(1) of the Food and Drugs Act in Canada. Unlicensed
healthcare goods cannot be advertised because the terms and any intended indications
have not been established. The advertising of any experimental medication or medical
device is expressly forbidden under the US Code of Federal Regulations (CFR), Title 21,
section 312.7(a) and 812.7(a).
The main concern with the promotion or advertising of unlicensed healthcare products or
off-label uses is that a healthcare provider may form an opinion about a product's use based
on its company's claims before it receives regulatory approval, and that opinion may be
incorrect in relation to the pending regulatory approval. Such an erroneous opinion on the
part of the healthcare provider could lead to improper use of the licensed medicine,
resulting in off-label usage of the product.
Advertising licensed healthcare products
An advertisement is defined as "any representation by any means whatever for the purpose
of encouraging directly or indirectly the sale or disposal of any food, drug, cosmetic, or
gadget," according to Section 2 of Canada's Food and Drugs Act.
Advertisements
Internet sites
Brochures
Exhibition panel
Gifts
Samples
Reprints
Product monographs
A sales representative’s activities
Training materials or briefings
Press releases
Meetings or symposia