Boehringer Ingelheim breached ABPI Code over Pradaxa 110mg website claim implying use in “any patient at increased risk of bleeding” (AUTH/3293/1/20)

📅 2020 | 🖉 Dr Anzal Qurbain
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Key facts

CaseAUTH/3293/1/20
ComplainantAnonymous (health professional)
CompanyBoehringer Ingelheim Limited
MedicinePradaxa (dabigatran); claim related to Pradaxa 110mg
Channel/materialWebsite landing page for Pradaxa 110mg (ref PC-UK-101787 V1)
Key claim“Pradaxa 110 is the only low-dose [novel oral anticoagulant] for stroke prevention in atrial fibrillation recommended for use in any patient at increased risk of bleeding*”
Panel concernClaim implied use in all increased-bleeding-risk patients despite contraindication in severe renal impairment (CrCl <30 mL/min); footnote/link did not cure the issue
Breach clauses2, 7.2, 9.1
SanctionsUndertaking received; Advertisement
Complaint received30 December 2019
Case completed18 December 2020
Applicable Code year2019
AppealNo appeal

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Reviewed by Dr Anzal Qurbain (FFPM) — ABPI Final Signatory

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What happened

  • An anonymous health professional complained about promotion of Pradaxa (dabigatran) by Boehringer Ingelheim Limited.
  • The complaint focused on the claim: “recommended for use in any patient at increased risk of bleeding”.
  • The complainant argued the claim could not be substantiated because Pradaxa is contraindicated in severe renal impairment (CrCl <30 mL/min), which may be relevant in elderly patients.
  • The complainant did not provide the material or context and could not be contacted for follow-up.
  • Boehringer Ingelheim provided the Pradaxa 110mg website landing page (ref PC-UK-101787 V1) that it said was current when the complaint was submitted (30 December 2019); the Panel based its rulings on this page.
  • The landing page stated: “Pradaxa 110 is the only low-dose [novel oral anticoagulant] for stroke prevention in atrial fibrillation recommended for use in any patient at increased risk of bleeding*”.
  • A small-font link (“See how to select the right dose of Pradaxa”) and a small-font footnote (“Pradaxa 110 is also recommended for patients over 80 years of age and patients currently treated with verapamil”) appeared beneath/alongside the claim.
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Outcome

  • The Panel ruled the claim was misleading because a busy health professional could interpret it as meaning Pradaxa 110mg could be prescribed to all patients at increased risk of bleeding, despite contraindication in severe renal impairment.
  • The Panel stated it was irrelevant that a link to further information existed; claims must be capable of standing alone without recourse to footnotes/links.
  • The Panel noted concern about referencing “over 80s” in the footnote given renal impairment risk increases with age.
  • Breaches were ruled under Clauses 7.2, 9.1 and 2.
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