GovWire

This is for vets, suitably qualified persons (SQPs), pharmacists, marketing authorisation holders (MAHs), manufacturers of veterinary medicines and wholesale dealer authorisation (WDA) holders.

This provides guidance on the advertising restrictions on veterinary medicine in the UK.

This guidance refers to the following distribution categories:

• Prescription Only Medicine Veterinarian (POM-V)
• Prescription Only Medicine Veterinarian, Pharmacist, SQP (POM-VPS)
• Non-Food Animal Veterinarian, Pharmacist, SQP (NFA-VPS)
• Authorised Veterinary Medicine General Sales List (AVM-GSL)

The Veterinary Medicines Regulations (VMR), as amended, set out restrictions on who may advertise veterinary medicines and to what audience.

You must not advertise a veterinary medicine that:

• does not hold a current UK or GB marketing authorisation (unless it is marketed in accordance with the exemptions for small pet animals), which includes:
  • medicines with suspended marketing authorisations
  • extemporaneously prepared products (also known as specials)
  • human medicines
  • medicines imported under the Special Import Scheme
• is only available on prescription (POM-V, POM-VPS and products prescribed under the cascade) to the general public

An advertisement for a veterinary medicine, intermediate feedingstuffs and compound feed, (but not coccidiostats or histomonostats) must:

• make clear that the message is an advertisement for the purpose of promoting the supply, sale, prescription, distribution or use of the product
• encourage responsible use of the product
• present the product in an objective manner
• ensure that all factual statements are consistent with the Summary of Product Characteristics (SPC) for the product
• not contain information that:
  • is misleading
  • makes a claim that is not in line with its SPC
  • may encourage improper use
  • might suggest a veterinary medicine is a feedingstuff or a biocide
• for prescription medicines: include a statement that prescription decisions are for the person issuing the prescription alone

You can find the full requirements under Regulations:

• 10, Advertising the Product
• 10A, Inducements and hospitality
• 11, Advertising of prescription products and products containing psychotropic drugs or narcotics
• 12, Defence of publication in the course of business

The offences for non-compliance with these requirements are under Regulation 43, (f), (fa) and (g).

What is considered advertising

Advertising is any activity in connection with a veterinary medicine that is aimed or designed to promote the sale, distribution, supply, prescription or use of the veterinary medicine, whether for profit or not. This includes supply of samples or sponsorship for those purposes.

This also applies to electronic advertising, for example, website banners, emails.Some examples of types of promotional adverts are:

• mail shot emails to customers
• postal flyers
• website banners or pop ups
• sponsored banners on internet search engines
• text providing information about animal illnesses that specifically promotes a particular veterinary medicine
• presentations and other verbal communications

What is not considered advertising

General public

Educational information aimed at giving a balanced overview of a disease and all available treatments may be made available to the general public as long as:

• products or brand names of prescription medicines are not mentioned
• all other advertising restrictions are met

Educational information may name active substances and contain a small strap line at the top or bottom of the article stating this information was provided by [company] makers of [product]

Vets

Educational information on treatment options and opinions on authorised medicines used in accordance with their SPC may be made available to vets.

Educational information on treatment options and opinions on medicines prescribed under the cascade, for example, authorised medicines used outside the terms of the SPC, human medicines or extemporaneous products, may be made available to vets, providing that:

• the material does not reference product names, including brand and trade names, although active ingredients can be referenced
• the material does not reference a company or business
• no company or product-specific recommendations or endorsements are given
• presentations are unbiased and factual
• all other advertising restrictions are met

The use of pictures of veterinary medicines in presentations must comply with the advertising restrictions. For example, there should not be brand names or company logos visible in pictures of products not authorised in the UK or products being used under the prescribing cascade.

It is considered good practice for vets to declare any affiliations to pharmaceutical companies when presenting treatment options and opinions to vets at conferences or training events.

Advertising prescription medicines

You can only advertise veterinary medicines classed as POM-V in promotions aimed at the following:

• vets
• pharmacists
• vet nurses
• professional keepers of animals this excludes antibiotic medicines which are prohibited from being advertised to professional keepers of animals, including farmers

You can only advertise veterinary medicines classed as POM-VPS in promotions aimed at the following:

• vets
• pharmacists
• suitably qualified persons
• other veterinary health care professionals
• professional keepers of animals

Advertising non-prescription medicines

There are no restrictions on the advertising of veterinary medicines classified as NFA-VPS and AVM-GSL as long as the:

• information in the advert isnt misleading
• claims are accurately taken from the products SPCs

There are no restrictions on the advertising of products that come under the exemptions for small pet animals.

Price lists

Price lists are not considered as advertising material as long as all products are listed with equal prominence.You must do all of the following to avoid your price list being classed as an advert:

• include a list of all products in a particular category, for example all prescription wormers
• use the same size text and images for all products
• use consistent font size, colour and formatting
• only use images that show the medicine with UK authorised packaging
• refer to the product by its full authorised name

You should also make sure the name of each medicine, its image and a description is in line with the products SPC.

Online search engines

Sponsored/paid for adverts on internet search engines are by definition an advertisement and therefore fall under the advertising restrictions set down in the VMR.
However, we recognise that search engines are a useful tool to help customers to shop online efficiently. Therefore, we consider it acceptable for online retailers to use these adverts to direct customers to their websites in response to a search for a specific POM-V or POM-VPS medicines.

However, the use of non-specific terms to advertise prescription veterinary medicines is not acceptable. For example, if a customer searches for the specific name of a prescription medicine in a search engine, an online retailer may name only that product and the price in the advert to direct the customer to their site. If a customer uses non-specific search terms such as arthritis in dogs or feline kidney problems this should not result in prescription medicines being advertised.

Medicine selection

You must use medicines based on their medical suitability rather than for any financial gain. Suppliers of medicines should not undertake promotions such as discounts or buy one get one free to try to influence prescribers of medicines.

Support advertising claims

If you are a products marketing authorisation holder you must make sure that any advertising claims you make are supported by information in the products SPC.



View the original news story