Insights

The use of testimonials and influencers is becoming increasingly common in healthcare. However, when advertising medical devices to the public in Italy, companies must carefully balance marketing objectives with regulatory requirements.

According to the latest guidance made available by the Italian Ministry of Health, the presence of a testimonial in advertising materials is not prohibited. Nevertheless, its role must remain purely neutral and should not result in any form of endorsement, whether explicit or implicit.

In particular, the Ministry considers the following elements critical:

• Testimonials may appear in advertising materials, provided they do not recommend or express a preference for the product.
• Implicit endorsement is also prohibited, even in the absence of direct promotional claims.
• Compliance concerns may arise where the testimonial:
  • displays symptoms related to the condition for which the device is intended;
  • appears alongside the product in a way that suggests personal use;
  • creates the impression of having used, benefited from, or intending to use the device.
• The Ministry of Health committee may object to the use of a well-known personality where communication could encourage inappropriate use of the product or raise public health concerns.

These principles are particularly relevant for influencer marketing. While an influencer may participate in a campaign as a communication element, greater caution is required whenever the content includes personal experiences, recommendations, or any association between the individual and the use of the device.

For companies, the practical takeaway is straightforward: visibility may be acceptable, endorsement is not.

RPN is available to support companies in the strategic assessment of promotional concepts and communication plans before submission to the Ministry of Health, helping identify potential compliance risks, and maximise the likelihood of a smooth authorization process.