Promoting responsible marketing practices

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Vision in Brief:

Consumer Health Products Canada and its member companies are seeking a marketplace where all marketers of consumer health products adhere to responsible marketing practices and all products are marketed in an equitable manner. When this vision is achieved, consumers will have access to all the information they need to select and use a product responsibly, and can feel confident that the information on all consumer health product labels and in advertisements is truthful.

Summary:

Building consumer trust and confidence in Canada's consumer health products is not only about providing Canadians with consumer health products that are safe, of high quality and provide the health benefits that are attributed to them, it is also about providing consumers with the information to select and use them appropriately. Consumer Health Products Canada's member companies are firm proponents of the adage about truth in advertising, so much so that they have their own code of marketing practices to which all members voluntarily adhere in addition to the requirements set out by Health Canada.

CHP Canada members are leaders in developing and adhering to responsible marketing practices, regardless of whether they are required or they are voluntary. Members believe that the practice of making unproven claims on product labels, in advertisements, on the Internet, and by store clerks makes it difficult for consumers to know what is true and what is not. Such situations can taint the whole industry and create an "unlevel playing field" in the marketplace.

Consumer Health Products Canada and its members believe that Health Canada needs to demand greater compliance to its guidelines and take enforcement actions against marketers that mislead consumers with false and/or unproven and/or unapproved marketing claims.

Vision in Detail:

Consumer Health Products Canada's members are leaders in encouraging responsible marketing practices across the industry. They have created their own code of marketing practices to which all members voluntarily adhere in addition to the requirements set out by Health Canada. This code promotes responsible marketing practices that covers everything from labeling, advertising and promotion, to the use of child resistant and tamper evident packaging.

In addition to creating their own voluntary code, CHP Canada's members are actively involved in providing their expertise in the development and review of the government's marketing policies. Noting that no formal guidelines existed for advertising that directly compared the benefits of competing consumer health products, CHP Canada's members insisted that strict guidelines had to be put in place to ensure that the claims would not be false or misleading. Health Canada accepted their recommendations.

CHP Canada members were also the pioneers in voluntarily submitting their advertisements to a third party agency to review their ads prior to broadcasting to be completely sure that the ads adhered to the requirements set out by the government. In 2010, the members went a step further by developing criteria for the size, contrast, and duration on-screen of the cautionary message in television advertisements to ensure it is legible to consumers.

When it comes to product labeling, our members are also leaders in ensuring consumers have all the information they need to select and use the product responsibly. The Association has two other voluntary guidelines to provide guidance to its members (and the rest of industry): Voluntary Labelling Program for Significant Changes to Products provides guidance members can use to alert consumers to significant changes in consumer health products; and the Technical Research Paper for Improving Label Comprehension can be used by marketers as a means to improve consumer health product labels to increase the overall comprehension by consumers. Our members also voluntarily list non-medicinal ingredients on their outer labels to ensure that consumers have access to that information.

CHP Canada members are leaders in developing and adhering to responsible marketing practices, regardless of whether they are required or they are voluntary. Members believe that the practice of making unproven claims on product labels, in advertisements, on the Internet, and by store clerks makes it difficult for consumers to know what is true and what is not. Such situations can taint the whole industry and create an "unlevel playing field" in the marketplace. 

The Solution:

Consumer Health Products Canada and its members believe that Health Canada needs to demand greater compliance to its guidelines and take enforcement actions against marketers that mislead consumers with false and/or unproven and/or unapproved marketing claims.

Advice for consumers: When consumers see the DIN or NPN numbers on a product, they can be assured that the information on the labels has been reviewed by Health Canada. Advertisements on Canada's major television and radio networks, mass media print, and outdoor ads have been reviewed by a government-recognized third party agency prior to approval.

CHP Canada Success to Date:

  • Consumer Health Products Canada implemented its own Code of Marketing Practices (updated 2004)
  • The Association researched and created two voluntary guidelines to assist members (and industry in general) in developing informative label information (1999 and 2001).
  • CHP Canada worked with Health Canada to set up a voluntary system for pre-clearing consumer health product broadcast advertising (1997). The Association continues to work with the independent third-party preclearance agencies on timely and efficient preclearance mechanisms to ensure that the voluntary system continues to work.
  • Health Canada agreed with CHP Canada's recommendation that allowing comparisons in product advertising would benefit consumers, as long as the comparisons were evidence-based.
  • CHP Canada worked with Health Canada and the independent third-party preclearance agencies to develop very strict guidelines for comparative advertising (2005).
  • CHP Canada provided evidence-based knowledge to Health Canada as it developed a new Consumer Advertising Guidelines for Marketed Health Products (for Nonprescription Drugs including Natural Health Products) and recommended that its members (and the rest of the industry) implement the guidelines as soon as it was put into effect. The Association was successful in having one section subject to a pilot period to determine whether or not it would indeed be useful in improving health outcomes.
  • In 2010, the members developed a voluntary guideline to help consumer health product marketers and advertising agencies ensure the legibility of the cautionary message in television advertisements. 
  • CHP Canada also worked with the Pharmaceutical Advertising Advisory Board (PAAB) to update portions of its code to reflect responsible marketing practices for advertising consumer health products to health professionals (2009).

CHP Canada in Action:

  • CHP Canada's Board of Directors has requested that Health Canada take greater enforcement action against marketers that do not comply with the government's regulations.
  • CHP Canada collaborated with Health Canada on consumer research to measure the degree of awareness of the risks associated with consumer health product use and the impact of a general cautionary statement in consumer health product advertising.