MLRagent

Risk information should not appear only on a brief summary page

DisputedwarningFDA guidance · non-bindingRaised as a question — a person decides

Rule

In addition to appearing with or near benefit presentations, risk information should appear as an integral part of a prescription drug print ad, just as benefit information does; a prescription drug ad should not present risks only on a brief summary page.

Check

Confirm the piece contains risk content integrated with the main promotional message, not solely on a brief summary page.

Escalate when

Reviewer cannot tell whether risk content outside the brief summary (e.g., below the logo/tagline or in a visually separate column) counts as an integral part of the piece.

Where this comes from

Section III.C.1, Location of Risk Information within a Part of the Promotional Piece · page 19. The highlighted words are quoted exactly; a script confirms they appear in the source before the rule can be published.

… Complete separation of benefit and risk information (e.g., presenting several pages of benefits before any risks) is one example of a lack of appropriate prominence. FDA will also look to see that risk information is not placed in such a way as to interfere with readers’ perceptions of the relative importance or utility of the information. \ Location of Risk Information within a Part of the Promotional Piece In addition to appearing with or near benefit presentations, risk information should appear as an integral part of the piece, just as benefit information does. For example, a prescription drug ad should not present risks only on a brief summary page. > Example 15: A product’s logo and a tagline are often used to signal the end of a piece. Readers > may assume that any risk information placed below the logo and tagline is there only for liability > purposes or to fulfill a regulatory requirement and is unrelated to the main message, especially if > the information is presented in small type or otherwise lacking in emphasis. > Example 16: A seven-page sal…
Document
FDA guidance: Presenting Risk Information in Prescription Drug and Medical Device Promotion (see document)
Version
as retrieved — the publisher does not version this document; the fingerprint below identifies the exact file
Retrieved
2026-09-21 from www.fda.gov
Fingerprint
f5654ab082f6cd4408143f16…

FDA guidance describes the agency's current thinking. It is not binding law, and this rule is a recommendation, not an obligation.