April 28,2006
DTCA consultation
Sector Policy Directorate
Ministry of Health
PO Box 5013
WELLINGTON, NEW ZEALAND

Dear Sir,
I am the Chairman of Medwatcher Japan, which is a non-profit
organization founded in 1997. It represents the interests ofpatients in drug policy and believes that all drugs marketedshould be acceptably safe, effective, affordable and meet real
medical needs.
Medwatcher Japan supports Option 3 ― Ban DTCA andregulate disease-state advertising (Therapeutic Products
Advertising Code + harmonization with Australia’s policy on
DTCA and disease-state advertising).
Currently, DTCA is officially prohibited in Japan. However,
we are faced with growing sales promotion pressure from drug
companies. Today, so many leading newspapers are carrying
various advertisements to recruit the subjects for clinical trials of
new drug development. This kind of advertisements is notregarded as DTCA, but in effect it works like a "diseaseawareness" campaign. Cleverly devised traps are hidden under
the disguise of an educational disease article in popularmagazines.
The story of Iressa (gefitinib) in Japan is one of such examples.
Before the new-drug application was accepted the drug company-1-

took advantage of every opportunity to promote Iressa as a"Wonder Drug" for cancer. Many patients scrambled to receive
this epoch-making new drug. Iressa was prescribed for morethan 15,000 patients within a few months after the approval and
177 deaths due to acute lung injuries within 6 months after thelaunching of Iressa. All of the trials published afterward
showed no benefit compared to placebo. If it were not for such a
big promotion, there would be far less victims of this tragedy.
Another example of DTCA in Japan is anti-depressant campaign
or widespread promotion of SSRI. Drug companies do not makea crude propaganda, but they adopt the style of enlightenment orscientific education. They generate consumers vague anxiety
through exaggerated expression, and try to induce them to takeantidepressants. In some cases, "disease awareness" campaign
will give patients earlier chance of diagnosis, and might bringthem some benefits.
Generally speaking, however, drug
companies are likely to overestimate the benefit, andunderestimate the risk of their products. They will exert theireconomical leverage and credulous people will be easily misled byfalse advertisements. We must admit that there is a lack ofcommunication between medical professionals and consumers.
To solve this problem, however, the introduction of DTCA willproduce the opposite effects.
As Lewis Thomas described in "Medusa and the Snail"(1979),"The trouble is, we are being taken in by the propaganda, and it
is bad not only for the spirit of society; it will make any
health-care system, no matter how large and efficient,
unworkable." This description here is about the US, but theseproblems are now becoming global situation.
Therefore, we are against the introduction of DTCA in ourcountry and have a deep concern over the New Zealand's decision
about DTCA. The Government of New Zealand has a great
responsibility for the health of the world.
We sincerely hope-2-

that New Zealand will make a judicious decision.
Very respectfully yours,
Toshihiro Suzuki
Chairman
Medwatcher JapanAM Bldg 4th Floor
1-14-4 Shinjuku, Shinjuku-ku
Tokyo, 160-0022 JAPAN
Phone: +81 3 3350 0607 Fax: +81 3 5363 7080E-mail : yakugai@t3.rim.or.jp-3-