What is an unbranded campaign?
Do you have horrible allergies? Recurring sinus infections? Irritable bowel syndrome? Sure, you’ll head to your doctor but you’ll also google around and look for information – it’s natural – so you’re better informed when you talk to your MD.
Pharmaceutical companies employ unbranded campaigns to inform the public about a specific condition. It’s like a PSA: a public service announcement for healthcare. The idea is to arm you with facts as well as to build goodwill toward the pharma or drug brand. And they are exactly what you’d think: unbranded. So there’s no prominent mention of the drug brand and no call to action on the unbranded content. But unbranded doesn’t mean there are no regulations. In fact, there are some additional rules to worry about.
Are unbranded campaigns easier to manage?
In some ways, yes, others, no. Unbranded campaigns are nearly as difficult and risky to manage as branded. So why use them at all? Well for one, approvals from legal and committees are generally much faster. And executives are more likely to approve unbranded campaigns, especially with influencers, because of perceived risk avoidance. Unbranded campaigns have a long tail, too. You can leave up the unbranded properties almost indefinitely, updating them as new information is published. The gift that keeps on giving.
They are faster to get approved through legal and medical committee because you avoid the tightly-dictated Dos and Don’ts of branded campaigns. But it’s not all a cakewalk: you still need to use FDA-approved language and monitor public comments for adverse event reporting. And unbranded campaigns carry some regulations not found in branded campaigns: “temporal proximity” and “suggestive content”, for two.
The former means how visually “close” the sponsoring pharma’s name or brand’s logo appears on the unbranded content web page or app as well as how many clicks away the brand’s content can be accessed. The latter is more qualitative: how closely reminiscent is the look and feel of the unbranded content to that of the pharma brand’s? Colors, fonts, styling all contribute. This is all esoteric so if you need some guidance, feel free to reach out to us.
“You Don’t Want to Talk About Poop?”
Some people don’t mind talking about their bowel movements (I’m talking to you, Dad), but turns out most people hesitate. Allergan chose a comic to be their spokesperson for their Toilet Talk campaign, aimed at making people aware of gastrointestinal issues. It features a poop emoji for a logo and a quick quiz.
Remember the two big rules for unbranded campaigns? Temporal proximity and suggestive content. The name “Allergan” is only displayed on the footer, and in grayscale. The logo is not hyperlinked but there is a linked “About Allergan”, which was an aggressive move on unbranded content.
For the suggestive content guideline, I think Allergan did a perfect job of keeping the look and feel different.
What will be in the new guidance?
But the FDA, or more precisely, the Office for Prescription Drug Promotion, which issues “guidance” for brands and agencies, is currently updating their formal guidance for unbranded campaigns. So there’s no current guidance, but you can certainly rely on past direction for your campaigns now.
What do we expect to see in the new guidance? Specific to influencers, we’ll probably see more definite rules on disclosure for #ad or #sponsored, similar to what the FTC issued recently, which states that it needs to be “above the fold” in an Instagram post. No more burying the tag in a comment or at the end of the post. This shouldn’t be an issue for any professional or semi-professional influencer and only a problem for programmatic platforms. But a lack of thorough content review and submission for programmatic takes that out of the question for any regulated brand.
But most important will be temporal proximity. We should see more definite rules on how many clicks or links to the brand from the unbranded page or post. And I suspect any branding whatsoever on the unbranded content will have to be unlinked. This would require Allergan to not use a linked “About Allergan” on any unbranded content.
To unbrand or brand?
Unbranded campaigns do carry a few extra regulations than branded campaigns but typically approve faster. In addition, the long tail of an unbranded campaign actually provides an educational service to patients so it will build goodwill with patients. However, consumers will yell if they perceive they’re being tricked by “big pharma”, which already has an image problem. So predicted changes regarding temporal proximity should only help with brand image and be embraced by pharmaceutical companies. Starting with an unbranded campaign then following it up with a branded campaign is a sound strategy; consumers are already aware of the information available and poised to accept an influencer’s recommendation for a medication.
About MATTR: MATTR, leaders in influencer campaigns for highly regulated industries, is the only full-service influencer marketing provider with detailed audience insights from PersonaMesh™. We go beyond demographics into psychographics such as values and interests so that your influencer campaigns align with your campaign targets.