The agency polices labeling and the advertising of products, and as such has a natural interest in new social media. “Regardless of character space constraints that may be present on certain Internet/social media platforms, if a firm chooses to make a product benefit claim, the firm should also incorporate risk information within the same character-space-limited communication,” according to the agency.
As such, the agency points out that benefits have to be accurately presented. For example, for a hypothetical drug, NoFocus, the agency argues that its manufacturer would have to disclose it’s for “mild or moderate memory loss” only, to avoid targeting the wrong patient population.
On the risk side, the agency recommends providing an associated resource providing a “more complete discussion of the risks associated with its product,” perhaps through a link in the original promotion. Since links often can take up a large percentage of a word count, the agency is fine with using link shorteners to condense the amount of content—and recommends that the custom link provide a clue as to what it’s pointing at in the text (e.g. bit.ly/drugrisk).
Of course, the agency also recommends that “at a minimum” the information presented in the communication should “include the most serious risks associated with the product.”
“If a firm concludes that adequate benefit and risk information, as well as other required information, cannot all be communicated within the same character-space-limited communication, then the firm should reconsider using that platform for the intended promotional message,” the guidance says.
The agency is also fine with punctuation and ampersands.
Follow Darius Tahir on Twitter: @dariustahir