For communications of "contextual use of a product name", that doesn't require preclearance, does it have to fall under the 5 criteria identified in section 1.5D of the code or does it simply not have to have a therapeutic claim or a promotional claim. ie. Does the statement "Call XXXXX for samples of product Y" require preclearance. ( as above no indication, no promotional claims, no therapeutic message attached) Thank you.
The above mentioned copy would not require PAAB review. Exemptions apply to the criteria outlined in section 1.5.