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When in Rome

The rules for advertising pharmaceuticals in Italy may sometimes appear contradictory

Have you ever been on holiday and cringed as another tourist, unthinkingly, did something inappropriate for the country and culture? It is close to the feeling I get when I see a so-called 'global' piece of communication, translated into different languages and thrown at the market.

Breathing out
Global often only means 'it-came-from-headquarters' with a recommendation that every market implement it locally.

By the time the concept gets to a market like Italy, where I live, all the big guns are excited about it and the concept is approved, produced and decided.

Approved, produced and decided, that is, by people who, culturally, are very different to most of the markets where it will be used. The result is either something alien or something so bland that nobody gets offended or excited: what offends the least Vs what impacts the most.

Strangely, this way of doing things is often described with the words efficiency and coherence.

I don't think so. You know that health systems are structured differently from country to country. You know that those systems change over time in every country as governments attempt to improve the quality of care and keep spending under control. You know that legislation changes dramatically from country to country and, even within one country, different rules apply to different products.

Diversity is complex: people speak different languages and have different interests, and it is the reason why humans dominate the planet; we adapt. We shape ourselves and our environment physically and culturally, from country to country, region to region, and city to city.

That is the reason why a global campaign should adapt from market to market.

German Chancellor, Willy Brandt, once said: If I am selling to you, I speak your language. If I am buying from you, dann m˙ssen Sie in meiner Sprache sprechen.

Language is only one reason why you need a competent local agency for your key markets. A local agency knows exactly what you can and cannot do, and will supply compelling opinions and options about what you should do based on experience and local knowledge.

Best of all, a local agency understands local culture because it is a part of it.

The flip side is that if you have every country working in isolation from each other, it can lead quickly to an incoherent global message. You can't win can you? Well, yes actually you can.


Breathing in
What you need is a concept, an idea, bold enough to be ownable and compelling, and broad enough to be something that any market can adapt locally.

Adapt. Not translate, not implement, but adapt. Where can you get ideas like these? How can you be sure that they work across boundaries? By breathing in before you breathe out. Create a globally sustainable brief, in collaboration with the marketing people in all your key markets, that contains the core values and goals of your brand.

Then tap into the huge resource that is your local agencies. Bring together creative people from different cultures that are key to you. Physically together, in the same place, for three or four days.

Lock them up in a big room with lots of pens and paper, coffee and an account manager who keeps reading out the brief and stops them from sneaking out to check the email; let the magic happen.

It is magic, I have been there. I have done this. It is very hard work, but also fun and rewarding. Let me take you there for a minute: it is the second day, people have split up and are working in groups.

You can easily make out seven different languages, but there are many more. The common language used to connect everyone is English, but the teams are free to work together in any language they choose.

There are two walls and windows totally covered with sketches and words. You come up with a great idea and share it with the others; some of them get excited but then the big Swede shakes his head.

Sadly, in his country the idea would not be understood and he explains why. Later it is his turn to have a concept he is excited about vetoed by a German colleague.

Normally, it would be very frustrating to have lots of great ideas killed like this, but this is different. You are not being told that your idea is not good, you are being told that it will not work in another country.

Not your fault, you couldn't know. But slowly you learn, and the work becomes more and more connected, increasingly stimulating. Ideas stand out because they are truly universal and exciting. When an idea clicks with everyone there is a silence. A kind of collective holding of breath, while everyone waits to see if some country has an objection or an issue.

If that silence lasts long enough, enthusiasm breaks through and all of a sudden all you can hear is: we could do it this way in my country...


Deep breaths
We could do it this way is what you hear when creatives see something they like and want to be a part of. Something that would work in their market and that they would feel good presenting to their local client.

Something in which they have a bit of ownership and will be passionate, not unhappy, about implementing. The result is good local work, done by good local people, based on a viable global idea they helped create, which keeps the brand coherent and significant worldwide.

Creation of the concept should not be the end of the breathing in and out. There is no point in getting together for the concepting if the development of layouts and qualitative testing is done by only one country. The production can be centralised to optimise costs but should continue to see the breathing in and out at work.

How do you do this? Enter the concept of a global network of local agencies. Not dots on a map, but people who really come together and work together. Not managers, but entrepreneurs who want to build companies, not just their careers.

Professionals, who sometimes spend more time working with people in another country than the people in the room next door. I don't like to think that technology has made the world smaller. I don't care to `think global'. I prefer to think that technology has made my local office and my local work much bigger.

Breathing in Italy
Now we have a globally relevant concept, it is time to make it work in Italy. I have tried to illustrate some of the rules that regulate Italian pharmaceutical advertising:

Any kind of information regarding a pharma product must be authorised by the Ministry of Health before being published.

The request for authorisation must be made in the correct way and requires 45 days for a response. Unless you have a lot of time to waste, make sure you submit material that will be approved - it takes experience.

For most OTC products, there are no great restrictions regarding who you can communicate to. You can do direct-to-consumer (DTC) advertising in any media.

There are some legal phrases that must be `speakered' on television and radio advertising (in print it's easier - they go in the small print). These phrases vary but are all quite long and would normally require about 10 seconds to read out; they are typically read very quickly and then speeded up. The result is a bit comic and not very comprehensible, but if you do not exaggerate when speeding it up, it's legal.

For prescription drugs, it is more restrictive as no DTC advertising is allowed. It is also useful to note that the distinction between what you can and cannot promote DTC does not coincide perfectly between OTC and prescription campaigns.

Consumer targeted disease awareness campaigns are allowed and can be a useful tool, but they must not make any reference to products. All claims must be backed and referenced by studies, so you will find that some headlines have a halo of small numbers around them. Also, all references must be to studies published in Italy, so often you have to find a local study to substitute content that came from global.

Last, but not least, there are no patient testimonials. You cannot use real patients in advertising, you can only use actors made to look like patients; the Lilly sales aid for Humalog (on the opposite page) uses actors to represent patients.

Never use actors to play doctors in DTC advertising. If you wish to use a testimonial from the medical profession in consumer advertising, it must be the real person and their credentials must be communicated.

These are just a few quick examples of the many rules and regulations that control pharma advertising in Italy (though they sometimes seem to contradict each other).

You really need to know all the rules to play the game. The bottom line? Find a good local agency that is co-operative and integrated fully with the rest of the world.

The author
Peter Comber is a partner and chief creative officer at DWA Health in Italy, a member of InVentiv Communications

2nd September 2008


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