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NOTE: This is an archived issue. The current issue of AgVetLink can be found at http://www.nzfsa.govt.nz/acvm/publications/agvetlink/
AgVetLink: Number 52, October 2005
Status of product branding
Certain prescription animal remedy (PAR) veterinary medicines are registered with a PAR condition primarily because veterinary diagnosis and decision that the product is suitable for use is necessary or because unwarranted or uncontrolled use may lead to risks to international trade. In such circumstances, it is considered unnecessary and detrimental to the ability of the veterinarian to select the most appropriate treatment if such products are being advertised to end users. Therefore, these products (e.g. antibiotics, anabolic steroids) will be approved with a specific condition that prohibits advertising to end users.
The ACVM Group has been approached with the following questions regarding the scope of advertising for PAR products such as antibiotics:
1. Is it advertising to use product brand names and trade names on merchandise such as pens, jotter pads, calendars and whiteboards that will be provided to non-veterinarians?
2. Is it advertiisng to include trade names, Material Safety Data Sheets, graphics of the label and product pack shots on company websites that are accessible to the public?
Following internal discussions it was agreed that such activity is not considered to be advertising as per the definition included in the labelling guide for the following reasons:
1. The use of brand or trade names in isolation from any information regarding the product is not considered to be an attempt to promote the product, but rather induce product recognition in users should they encounter it later.
2. It has been previously accepted that approved traders may advise customers what products they stock, which in effect will result in lists of product trade names being publicly available.
3. The ACVM website already includes basic product information and complete approved label text.
An opportunity is being provided for industry to comment on this interpretation. All comments will be analysed and the final policy advised in the next AgVetLink. The advertising section of the labelling guide will then be updated accordingly.
Comments should be sent no later than 15 November 2005 to:
Jennie Moran, Approvals and ACVM Group
PO Box 2835, Wellington
New Zealand Food Safety Authority
68-86 Jervois Quay
PO Box 2835
Wellington
NEW ZEALAND
Phone: +64 4 894 2500
Fax: +64 4 894 2501
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