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Does the agreement make any distinction about "Direct Response" commercials?

This depends upon the nature of the production. If a direct response offer is produced as an infomercial, sometimes called a long-form commercial, it is not covered by the collective bargaining agreement. On the other hand, if a direct response offer is made in, e.g., a :30 format and aired on television, it would be a covered commercial.  The best policy is to use Ad-ID on all assets to be certain reports that do need to be filed will be free from errors.