Advertising and Rewards for Certain 💉

The Australian Government’s Therapeutic Goods Administration website states: “Some therapeutic goods, including prescription and certain pharmacist-only medicines, as well as biologicals (things such as vaccines, for example), are prohibited from being advertised directly to the public.” They’re very clear on that. It makes sense, right? When we feel sick, we can go see a doctor and they can prescribe a medication to us if they deem it necessary. It’s not a perfect system, but certainly, if advertisers had free rein, knowing that these giant pharmaceutical companies have very deep pockets, we’d end up with ads for tetanus injections and heart medications. So that’s why I found it unusual, but perhaps unsurprising, that there’s an exception to the rule, and I think you might be able to guess what for.

TGA Communicating about COVID-19 vaccines
https://www.tga.gov.au/resources/resource/guidance/communicating-about-covid-19-vaccines

Advertising COVID-19 vaccines. “The advertising of prescription medicines (including vaccines) to consumers is generally prohibited in Australia. However, the use of specific promotional materials to advertise COVID-19 vaccines has been authorised to support the roll-out of the vaccines across Australia.” We’ll be looking at this page: “Advertising COVID-19 vaccines to the Australian public”. Communicating about COVID-19 vaccines, noting this was updated on 20 December 2022.

Scrolling down to the section “Self-developed materials”, it says: “The TGA has issued subsequent legal permissions (the 2022 permission) that allows advertisers to develop their own materials to communicate publicly about COVID-19 vaccines subject to the conditions below.” There are a whole bunch of conditions, but the main ones are: “The content does not contain any reference to trade names, or active ingredients, or any reference to the name of the sponsor or manufacturer”, so you can’t say “Pfeezer” or “AstraZonica”; “The content does not contain any statement, or implication comparing different COVID-19 vaccines (or comparing vaccines with treatments such as medicines)”, so you can’t say “Pfeezer is better than AstraZonica”; You can’t include “statements to the effect that COVID-19 vaccines cannot cause harm or have no side effects”, so it’s apparently illegal to say “Pfeezer is 100% safe”; And of course, you can’t include “any statement regarding COVID-19 vaccines that is false or misleading”, “Pfeezer can help you find a girlfriend” [clears throat].

But the most unusual rule I found, which perhaps you don’t find very surprising, is that you can legally be offered a reward! “Under the 2022 permission, any party can offer valuable consideration (cash or other rewards) to people who have been partly or fully vaccinated”. There are a few conditions, for example, “rewards must not include tobacco or medicines”; “the offer must only refer to COVID-19 vaccines generically”, that is, you can’t only give people a reward who take “the mRNA vaccine”; And perhaps most surprisingly (or not), “an offer of alcohol must not encourage excessive or rapid consumption of alcohol, have a strong or evident appeal to minors and must be served consistent with the Responsible Service of Alcohol arrangements”. So yes, you can reward people with alcohol! (But not evil tobacco!).

The TGA have provided some compliant examples: “Fly Away offers a 10% discount on flights to all 'Fly Away Club' members who have either been partly or fully vaccinated under the Government's national COVID-19 vaccination program”; “Dramatic Days theatre company publicly offers a chance to win a years' worth of free theatre tickets to anyone who is partly or fully vaccinated”; “The Reds Soccer Club offers free tickets to a game for anyone who is partly vaccinated”, if you’re fully vaccinated, p**s off! And just one more: “Uptown Medical Centre and Pharmacy publishes a Facebook post offering a free health check to anyone who has been partly or fully vaccinated” – Uptown funk you up!

And in other news, new NSW Premier Chris Minns said that vaccination is the best way to protect yourself from the harmful effects of flu, and not only that, it’s free!

So what did we learn from this video? Well, in Australia, you can offer people cash to take a COVID-19 vaccine. You can give them discounts. You can even legally offer them alcohol! But tobacco’s a big no-no, and you can’t say – and this is an exact quote so I cannot get in trouble, “statements to the effect that COVID-19 vaccines cannot cause harm or have no side effects”.

Is it just me, or are these TGA rules really bizarre?

COVID-19 vaccine advertising and import compliance
https://www.tga.gov.au/products/covid-19/covid-19-vaccines/covid-19-vaccine-advertising-and-import-compliance

TGA Advertising: Getting started
https://www.tga.gov.au/how-we-regulate/advertising/how-advertise/advertising-getting-started

MUSIC
Allégro by Emmit Fenn