Even though the FDA did not respond to what defines advertising, they did say that advertisements would appear in the following:
Billboards and/or Posters
Magazines and newspapers
Electronic Mail Correspondence
Electronic mail correspondence includes mobile phones, smartphones, social media or other forms of communication.
Websites and applications that allow the sharing of audio, video, or photo files along with video and audio promotions and other items that are not subject to the sale or distribution. Tobacco products are subject to the FDA and Cosmetic Act.
That said, the FDA stated they would issue more guidelines for effectively providing warning labels for some of these mediums.
In 2017, the FDA required that manufacturers and retailers who planned on advertising must have submitted their advertising plans. The opinion of this guideline, retailers and manufacturers would not be punished for not supplying their advertisement plans until 2018. The FDA continually encouraged those who were under the advertising requirements should have submitted their plans before August 2018. This would allow the agency to work with companies to help them become compliant.
The agency did not believe submitting advertising plans for compliance would delay production as long as manufacturers followed the guidelines which would be released over the following 12 months. The FDA went on to say they had received a higher than expected number of advertising plans and therefore would extend the compliance period so no manufacturer would be forced to wait to advertise because of delays from the FDA.
To date, these guidelines and requirements are in place and the FDA has stated that it does not know of any situation in previous regulations where a company was delayed by the FDA's requirements.