The pharmaceutical industry’s promotion of opioids in North America has been well-documented. Yet despite the clear consequences of improperly classifying pharmaceutical company messaging and frequently permissive approaches that allow the pharmaceutical industry to self-regulate its own advertising, there has been scarce investigation to date of how pharmaceutical industry stakeholders interpret definitions of “advertising.” This study explores how variations of “marketing” and “advertising” are strategically framed by the different actors involved in the manufacturing and distribution of pharmaceutical opioids. We employed a framing analysis of industry responses to Health Canada’s letter to Canadian manufacturers and distributors of opioids requesting their commitment to voluntarily cease all marketing and advertising of opioids to health care professionals. Our findings highlight companies’ continuing efforts to frame their messaging as “information” and “education” rather than “advertising” in ways that serve their interests. This study also calls attention to the industry’s continual efforts to promote self-regulation and internal codes of conduct within a highly permissive federal regulatory framework with little concern for violations or serious consequences. While this framing often occurring out of public sight, this study highlights the subtle means through which the industry attempts to frame their promotion strategies away from “marketing”. These framing strategies have significant consequences for the pharmaceutical industry’s capacity to influence healthcare professionals, patients, and the general public.