Wednesday, October 14, 2009

Boehringer's Branded Tweet Violates FDA Regulations Just Like Those 14 Paid Search Ads Did

Today marks another first for pharma's foray into the murky world of social media marketing. Boehringer-Ingelheim (BI), the German pharma company, just posted the following branded Tweet via Twitter:

The link in that Tweet leads to this press release, which provides the details, including fair balance (eg, side effects).

The press release also states:
Please be advised
This release is from Boehringer Ingelheim Corporate Headquarters in Germany. Please be aware that there may be national differences between countries regarding specific medical information, including licensed uses. Please take account of this when referring to the information provided in this document. This press release is not intended for distribution within the U.S.A.
About two-thirds of my Twitter followers are based in the US. According to this source, 62% of ALL Twitter users are US based. Therefore, it is difficult for me to imagine that BI did NOT intend this Tweet to be distributed within the U.S.A.

So there's THAT criticism of this Tweet. I also criticize it for violating FDA regulations (and maybe ABPI guidelines as well).

BI's branded tweet goes one better -- or worse, depending on your viewpoint -- than Novo Nordisk's Levemir branded Tweet (see Novo Nordisk's Branded (Levemir) Tweet is Sleazy Twitter Spam!). Namely, it mentions BOTH the product name AND the indication without including within it the fair balance. It is, therefore, very similar to the paid search ads that the FDA said violated the law (see "FDA's Actions Speak Louder than Its Words: On the Internet It's the Medium as Well as the Message!").

Up until now, BI has been very careful to avoid this sort of thing in its Tweets. I wonder if this was some kind of oversight, because it doesn't make much sense to issue such a branded Tweet in the USA or anywhere else.

For more about BI's social media strategy, listen to this podcast in which I interview Judith von Gordon and John Pugh, external communications executives at Boehringer Ingelheim ("Pharma on Twitter: Boehringer Ingelheim").


  1. Hi John

    In response to some of your claims I’d like to share with you our point of view.

    Our published Twitter bio clearly states, “This is the official global Twitter channel for Boehringer Ingelheim”. The key point here being global. Our location is stated as: Ingelheim, Germany. To avoid confusion we opened BoehringerUS, a channel for US specific tweets, back in August. I think we’ve made it clear that the boehringer channel is not US specific, it is global.

    Furthermore, of the 2,988 followers we have for our global profile, according to Twitter Analyser, 974 are registered in the USA. That’s roughly 33.5%. Which means that the majority, almost two thirds, are non US based. I'm sure every Twitter profile is different, depending upon who they are, where they are and howthey approach Twitter.

    Also, the tweet states that the ruling is made for the EU; it is clearly directed to EU followers. The press release the tweet is directed reiterates this, as you kindly published.

    Finally, in the US Mirapexin or Sifrol is marketed as Mirapex. We didn't mention that brand name in the tweet.



  2. I am surprised it passes EU regulations when the equivalent here in the US would clearly be a violation of FDA regs. Seems DTC advertising is allowed in the EU!

  3. DTC in Europe! Without PI!!

    When did that happen?


  4. Anonymous5:25 PM

    Insider , it has PI on side effects in the press release.

    Under: About Mirapexin®/Sifrol® (pramipexole)

  5. Ah, the "two-click" rule!

  6. Anonymous9:37 AM

    you are so lost with all this so-called social media crap. So companies can't annouce that a product was approved in europe without raising issues at FDA? Since when?

  7. What about raising issues with EU regulatory authorities?


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