By Mark Land, AAHP President
As our article on online marketing techniques shows, there’s great opportunity to increase product awareness and sales. But take caution; Do not do so at the expense of lowering the reputation of your company or the homeopathic industry. There are many tempting gray areas.
One not-so-gray area is labeling an over-the-counter drug for a serious condition or enable consumers to treat a serious condition without doctor supervisor by providing access to what should be a prescription drug. This type of marketing and poor GMPs are the basis of all recent FDA warning letters to homeopathic manufacturers and subsequent negative media coverage. For this reason, I hope you will also review “Compliance Hot Spots to Watch” and AAHP’s position statement on the emerging coronavirus.
During many public health crises such as Swine Flu, Ebola, SARS and even the 2001 anthrax attack, there was always an opportunist or a well-meaning person making an inappropriate therapeutic claim for a homeopathic product. Beyond these extraordinary global health events, take care to monitor and correct how your everyday products are positioned on third-party websites. Review short descriptions used by online retailers for consistency with products labels.
Online marketing should be managed as you would manage other labeling and advertising of products:
- Do not make a statement through a consumer or expert that your company could not make directly. This includes paying to boost a third-party post that may slightly exaggerate a product claim.
- Do not boast of more than typical results.
- Pictures count! Don’t imply a treatment for which the product is not labeled.
- Don’t lead Internet users to a product by purchasing search terms for a condition beyond the product’s scope.
- No one likes clickbait and spam emails.
In the fast-paced digital age, new issues arise almost as quickly as the technology develops. A good rule of thumb is to remember that the same consumer protection laws that apply to commercial activities in other media apply online, including activities in the mobile marketplace.
- Federal Trade Commission, Dot Com Disclosures: How to Make Effective Disclosures in Digital Advertising (March 2013). https://www.ftc.gov/sites/default/files/attachments/press-releases/ftc-staff-revises-online-advertising-disclosure-guidelines/130312dotcomdisclosures.pdf
- United States Food and Drug Administration Guidance for Industry: Internet/Social Media Platforms with Character Space Limitations—Presenting Risk and Benefit Information for Prescription Drugs and Medical Devices (June 2014). https://www.fda.gov/ucm/groups/fdagov-public/@fdagov-drugs-gen/documents/document/ucm401087.pdf