The comments are in on the FDA’s proposed study of the effects of spokes-characters in pharma advertising. While six pharma companies offered suggestions on study design and wording, many more consumers took the opportunity to diss the whole idea of animated characters in ads altogether.
The FDA received 22 comments in the required 60-day filing period from individual people all recommending the ban of spokes-characters in drug ads, with most people also calling for a ban on DTC ads completely. A typical comment read, in part: “Limit the use of animation in prescription drug commercials. In fact, you should limit the commercials themselves.”
The FDA characterized the consumer comments as “out of scope of the proposed project” and did not reply to them in its second filing for comment last week. However, the consumer commentary does point out the current zeitgeist of consumer enmity for pharma. An FDA spokeswoman declined to comment on either the consumer or pharma remarks in an email exchange with FiercePharma, referring back to the original transcripts.
The six pharma companies that did ask pertinent questions and got responses were AstraZeneca, Merck, AbbVie, Regeneron, GlaxoSmithKline and Eli Lilly. The FDA posted a required 30-day public notice last week with its replies to the more than 30 specific pharma suggestions on the proposed questions and design of the study.
One of Merck’s comments showed concern about potential regulations, noting that the FDA study findings “may not translate readily into FDA DTC policy/guidance.” But the FDA disagreed, and while it didn't promise policy, it alluded to the possibility, writing, “On the contrary, this particular study has the potential to directly influence policy in an area that we have no prior research on. … Because there is no previous research of this kind, this will be an informative study that will help FDA develop guidance and policy in the future, should the research reveal a need to.”
The design of the FDA study sets up two different faux drug ads for two different conditions, using animated characters as well as a control ad with a live actors in tests that will include more than 1,500 participants. The FDA’s intent is to look at the effects of animation on viewers of pharma ads in specific areas. While previous studies have shown that advertising spokes-characters influence product attitudes and risk perceptions, the FDA wants to look specifically at how animation strategies--for instance, ones that symbolize the disease versus the benefit--and product characteristics--such as low-risk medication versus high-risk medication--influence perceptions.
The FDA will continue to take comments on the study through Nov. 25. The spokeswoman could not give a concrete study start date after that, but said “we will share updates with the public on the status of this study, as with all of our social science research, on our website.”
- read the FDA filings and submitted comments
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