Google has announced a new advertising policy for pharmaceutical companies that presents significant issues and dictates immediate changes.  Effective July 20, pharmaceutical companies can no longer run pharmaceutical ads in the so-called “Black Box Ad Format” – a format that had previously been approved by the FDA.  Instead, pharmaceutical companies will now have to run their ads through Google’s standard text ad unit.  Although Google has proposed some alternatives to the Black Box Ad Format, it is unclear whether the proposed alternatives will comply with FDA requirements.  Additionally, effective January 12, 2016, Google will no longer permit pharmaceutical companies to use vanity URLs (e.g., linking to a blood pressure drug website).  Google has historically prohibited vanity URLs for all industries except the pharmaceutical industry.  A full description of the changes can be found in our latest post on Reed Smith’s Life Sciences Legal Update blog.

The Bottom Line:  If pharmaceutical companies have not already done so, they need to contact their media buying agencies and be certain the agency is aware of the changes and is implementing acceptable work-arounds.