Principles and Practices for How Sharethrough Native Ads Comply with the FDA Guidelines for Advertising and Promotion
What Is This Document?
This document provides background for Promotional Review Committees seeking approval of native ads. Specifically, it documents Sharethrough’s principles and practices for designing a native ad product that meets the FDA and FTC guidelines for prescription pharmaceutical ads.
This document was created in partnership with outside counsels who are regularly involved in legal approvals of pharmaceutical ads and Promotional Review Committees.
Native advertising has emerged as the predominant media strategy for digital marketers looking to reach consumers on the web with targeted, respectful, and persuasive messaging. For the prescription pharmaceutical category, new media categories require careful attention to disclosures. The question is: can native advertising be a successful and legal tactic for pharma advertisers?
Sharethrough has spent years developing a product offering that follows the FDA and FTC guidelines for online advertising and promotion. Below is an outline of those principles and practices.
Native Advertising Defined
Native advertising is defined as: “a form of paid media where the ad experience follows the natural form and function of the user experience in which it is placed.” For example, every ad that appears as a user scrolls through the social feeds of Facebook, Instagram or Twitter are native ads that fit the form (look and feel) and function (users are there to discover content).
Sharethrough’s native ads follow the same principles of these ads, but instead of rendering to the form and function of those social sites and apps, they render to fit the design of the news and publishing sites on the web, such as Forbes, Health.com, WebMD, People.com, etc.
Principles of Sharethrough Native Ads for Pharma
Sharethrough’s native ads are built on the same principles of social sites like Facebook, but built in a way that allow the ads to scale and fit into site designs across the open web. The main principles with which these ads are built are:
- The ad fits in with the user experience, instead of interrupting the user experience.
- The elements of the native ad fit with the design of each publisher’s site. Elements include fonts, colors, thumbnail size and text size.
- Each ad is clearly labeled in accordance with FTC native ad guidelines so a “reasonable consumer” understands that it is a paid advertisement. The FTC guidelines provide insights and recommendations “into how consumers perceive search and native ads and how modifications to disclosures, including to disclosure language, position, text size, and color and to other visual cues such as borders and background shading, may enhance consumers' recognition of these ads.”
- For pharmaceutical advertisers, the safety information must be as prominent as the benefit information.
- All ads are clickable, and upon click, the user arrives at a page determined by the advertiser, a page where even more safety information is present.
Adapted for Pharmaceutical and FDA Guidelines
In 2016, Facebook added an “automated scroll” feature to their pharma ads so brands could include all the necessary important safety information and legal information required by the FDA. Sharethrough added this same feature to their native ads to fit all the legal requirements of prescription drug advertising on the internet.
Sharethrough native ads now include all the elements required to meet the FDA guidelines to promote any of the three types of prescription drug ads: Product Claim Ad, Reminder Ad and Help-Seeking Ad.
Requirements for Promotional Review Committees
The final step for most individual pharmaceutical companies is to submit Sharethrough native ads to their promotional review committees. Below are the elements typically submitted to these PRCs. Sharethrough can also help customize these with the proposed images and copy the brand plans to run.
1. Elements of native ads
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- Headline(s) 90 Characters Max Including Spaces
- Thumbnail(s) Image of any format. 1000x750 pixels or larger (4:3 ratio)
- (or Video) Video File (MP4, 1GB max) at least 720p video quality in MP4 format
- Disclosure: “Advertisement” or “Ad” is always present
- ISI text No character limit
- Click-through URL The destination that the user goes to upon clicking on any area of the ad
Variable Elements Provided by Brand
Static Elements Defined by the Ad Format
Brand/Product Name — Brand name (and generic name) to always appear in ad unit
Disclosure — “Advertisement” or “Ad” is always present
Headline(s) — 90 Characters Max Including Spaces
Headline(s) — Text size and color is defined by the ad format
Thumbnail(s) — Image of any format. 1000x750 pixels or larger (4:3 ratio)
Thumbnail(s) — Size and position is defined by the ad format
ISI text — No character limit
ISI text — Positioned in line with the ad, presented as prominently as the benefit information
Click-through URL — The destination that the user goes to upon clicking on any area of the ad
Click-through URL — Any click on the ad takes the user to the destination page defined by the advertiser
2. Three locations a native ad can appear per site
A. In feed
B. Mid article
C. End of article
3. Permutations of a native ad
A. Thumbnail/video on top, headline, disclosure, ISI
B. Thumbnail on left, headline, disclosure, ISI
C. Thumbnail on right, headline, disclosure, ISI
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