Answer was provided by the ANA-4A’s Joint Policy Committee (JPC). 

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.