Lantern Insights: Navigating Meta's Updated Data Sharing Restrictions for Health & Wellness Advertisers
We wanted to share what we at Lantern have learned about the upcoming restrictions on data sharing with Meta for health & wellness advertisers. We have updated this memo based on their revised communication on 12/8 here. See the original Meta communication here.
Categorization
Meta is categorizing health advertisers into two buckets: Fully Restricted and Partially Restricted. The exact ruleset that determines whether an advertiser is Fully Restricted vs. Partially Restricted is not entirely clear. Most advertisers in the U.S. will fall into the Partially Restricted category. Â
There are at least 3 categories of health advertisers (by domain)
- Health & Wellness Providers - will be Partially Restricted
- Health & Wellness Condition - will be Partially Restricted
- Patient Portal - will be Fully Restricted
Fully Restricted
Fully Restricted advertisers may not bid on any standard or custom events on conversion optimized bidding (i.e. “sales” campaigns) and will instead be limited to on-meta lead ads, traffic, awareness and engagement campaign objectives.
Partially Restricted
Partially Restricted advertisers cannot bid on any low funnel (add to cart, purchase) standard events but can still bid on upper / mid funnel events and custom events that correspond to a mid-funnel objective (i.e. a quiz completion, pre-purchase). Â
Note that the restrictions are set by web property, not company. A company could theoretically have an ad account (and data sources) that is partially restricted, but a different property that is fully restricted.
We have seen many false positives - clients outside of health flagged as Health & Wellness data providers. Meta is crawling their advertisers’ sites to make these determinations - which are fairly subjective in nature. Expect a lot of mistakes and don’t be afraid to appeal.
What is Allow / Disallowed - Beginning January 2025
- Allowed (for Fully and Partially restricted advertisers)
- Optimizing for certain campaign objectives, such as Awareness, Engagement, and Traffic
- Allowed (for Partially Restricted advertisers)
- Optimizing for upper funnel events: Landing Page Views, Donate, Search, ViewContent, App Install, and Search
- Using on-Meta events (i.e. lead forms on Meta)
- Optimizing for custom events (using CAPI) that are "indicative" of a future purchase
- For example, optimizing based on the answer to a question in a quiz / intake flow that a brand knows is correlated with purchase
- Gray Area (for Partially Restricted advertisers)
- The definition of “indicative” is unclear - so partially restricted advertisers may be able to optimize for mid-funnel events like lead and intake call - or post-purchase events -  as long as the event is set as a custom event
- It is up to advertisers to remain compliant with Meta’s restrictions; firing a custom event in the same funnel spot as a standard event does not appear to be compliant.
- The definition of “indicative” is unclear - so partially restricted advertisers may be able to optimize for mid-funnel events like lead and intake call - or post-purchase events -  as long as the event is set as a custom event
- Not Allowed (for all categorization levels)
- Optimizing for lower funnel standard events (e.g. Purchase)
- Optimizing for custom conversions (in Meta UI). Though custom events are allowed for partially restricted advertisers as previously stated. More on custom events vs. conversion in the appendix below.
Survival Checklist
One note on timing: though the official rollout date is January 6th, there WILL be an option for advertisers to opt into delaying the time where the restrictions will take effect by 30 days. This is because Meta knows January is the peak season for most health & wellness advertisers and wants to give advertisers ample time to prepare (and also to realize the ad revenue from January).
From Meta communication 12/8/24:
‍
Jan 6th-13th: 

Rolling notifications - we will give advertisers (on a rolling basis) 7 days to click a “more time” button in Events Manager to get additional 30 days, if they need it to address these changes.
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[IMPORTANT] 

Please ensure that if you need more time to address these changes, you must click the "more time" button within their 7-day period (e.g., by January 13th for those notified on January 7th, or by January 20th for those notified on January 13th). Failure to do so will result in these additional restrictions being applied between January 14th-21st, depending on your individual 7-day period deadline, and we will be unable to make any exceptions.
Immediate Actions
- Prepare for a post-pixel world. By late-Q1 / Q2, no health & wellness brand should be using the Meta pixel. This doesn’t mean brands need to remove it immediately, but be prepared to do so early next year. 

- Consider using a HIPAA-compliant CDP - Ours Privacy or Freshpaint. This can expedite the shift to CAPI, and while using one of these will not negate the need to follow Meta’s new guidelines, they will help advertisers improve their HIPAA compliance.
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- Any brand flagged as fully restricted should request a review.

- Launch new campaigns ASAP to test

- New events further up in the funnel

- Creating Custom Events with generic names
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Q1
- When you see the “more time” notification in Events Manager UI, opt in immediately to delay restrictions from taking effect for 30 days. You will only have 7 days from when the notification displays to opt in before restrictions take effect.
- Keep existing campaigns in place post-January 6th. Meta has stated they won't block existing campaigns, they'll just degrade performance over time.
- Stop using the Meta Pixel. Shift to a purely CAPI implementation.
- Take a close look at website funnels, and consider adding in more intermediary steps to gain signal ahead of actual purchase. For example - consider testing a quizflow to gather more information on potential customers that may correlate to purchase. And / or add pageview events post-purchase to trigger custom events. Â
- Don’t rule out reframing the role of Meta in your stack. Using Meta to build awareness and then harvest that demand through a lower-funnel tactic like paid search might be efficient for many brands. For example: companies with a narrow and easily defined customer target (e.g. Men above 65 in the Seattle and Portland MSAs) might do fine optimizing for traffic and engagement. Â
- Increase focus on Lifecycle Marketing and sequential retargeting series - as any up-funnel move will capture users less likely to convert immediately.
- Though Meta hasn’t explicitly commented on retargeting, Fully Restricted brands should test other channels for retargeting.
- Accelerating testing of newer upper funnel channels and tactics. This could include Youtube, Google Demand Gen / PMAX or Tiktok. We’re running more frequent channel tests (some interesting things happening on Reddit) and looking at offline channels earlier in clients’ lifecycles.
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Appendix: Custom Events vs. Custom Conversions
From Meta’s 12/8 communication


Custom conversion (on Meta Events Manager) will not be allowed with new and upcoming data restrictions since they are based on standard event which will soon be out of scope for optimization. HOWEVER, you can still use custom events for optimization . When doing this, all custom events must be registered to help ensure compliance with our Meta Business Tool Terms and follow legal restrictions. Advertisers must keep in mind that the event should not directly or indirectly share prohibited information. About standard and custom website events
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