Social Media Claim Essentials: Making Effective and Compliant OTC Drug Claims on Social Media in a Time of Evolving Agency Directives
Meghan G. Walters Price
Director and Assistant General Counsel
The Procter & Gamble Company
Kristen Klesh
Partner
Loeb & Loeb LLP
When dealing with non-traditional advertising tactics such as influencer marketing, online celebrity endorsements, bloggers or consumer reviews, OTC drug companies must be diligent in ensuring that claims about their products are thoroughly substantiated, appropriate disclosures are made, and
compliance teams are aware of the latest regulatory guidance and concerns. This panel will explore topics including:
- Determining how to compliantly promote your product and win consumer confidence while staying out of trouble with the regulators
- Examining how new FTC substantiation guidance, endorsement disclosure guidelines, and enforcement activity around use of consumer reviews are impacting social media and other online marketing by OTC drug companies
- Developing best practices for:
- Consumer endorsements and consumer reviews
- Expert, celebrity, and influencer endorsements
- Reviews on third-party websites
- Repurposed reviews
- Disclosures of material connections to the brand or seller of the advertised product