As we continue to work on our approach to the Health and Care Bill legislation and to collate your queries and examples for CAP to feed in to their discussions with government, it’s clear that there are still many areas which remain to be clarified.
Chief among these is the nature of the exemption in the legislation for brand advertising, about which members have raised specific questions, including how it will work in practice with regards to ranges of products, and what counts as a ‘brand’ – an umbrella product range name, or a company name, for example.
In order to explore these and other outstanding issues, we intend to convene a meeting of the group with CAP. We are, of course, in the middle of the passage of the legislation, and in the absence of its final form and the designation of the day-to-day regulator, CAP can at this stage proceed only on the basis of its initial judgments and precedents.
However, we hope that this meeting will provide a further opportunity for ISBA members to highlight concerns and views.