Veterinary Medicines Advertising Frequently Asked Questions (FAQ)
Veterinary Medicines Advertising Frequently Asked Questions (FAQ)
Veterinary Medicines Advertising Frequently Asked Questions (FAQ)
January 2014
Veterinary Medicines Advertising
Frequently Asked Questions (FAQ)
The Veterinary Medicines Regulations (VMR) set out the advertising restrictions for
veterinary medicines in the United Kingdom. The advertising restrictions aim to help
safeguard and promote the responsible use of veterinary medicines.
The VMD consider advertising to include anything that is aimed or designed to
promote the supply, sale or use of a product whether or not for financial gain. This is
regardless of the media used (e.g. TV, magazine, email or website).
This FAQ document lists many of the commonly asked questions we receive
regarding advertising, it should be read in conjunction with the VMR and Veterinary
Medicines Guidance Note 4: Controls on Advertising both of which are available on
the VMD website: www.vmd.defra.gov.uk.
General points on advertising
It is an offence under the VMR for a product available on prescription to be
advertised to the general public.
Advertisements for products classified as Prescription Only Medicine Veterinarian
(POM-V) may only be advertised to:
veterinary surgeons
pharmacists
veterinary nurses and
professional keepers of animals (except antimicrobial products*)
*For the purposes of this section an antimicrobial product means an antibiotic, which is antibacterial in
its action.
Advertisements for products classified as Prescription Only Medicine Veterinarian,
Pharmacist, Suitably Qualified Person (SQP) (POM-VPS) may only be advertised to:
veterinary surgeons
pharmacists
SQPs
other veterinary health care professionals
professional keepers of animals
There are no restrictions placed on the advertising of NFA-VPS, AVM-GSL and
products marketed under the Exemptions for small pet animals in terms of the target
audience.
It is an offence to advertise an unauthorised veterinary medicine.
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January 2014
All suppliers
6. Can I advertise an unauthorised veterinary medicinal product, ie a
veterinary medicine that does not hold a UK Marketing Authorisation?
No, it is an offence to advertise an unauthorised veterinary medicine.
Changes to advertising with effect from 1 October 2013
1. Can antimicrobial medicines be advertised to professional keepers of
animals?
No. The advertising of anti-microbial medicines to farmers is no longer
allowed. It should be noted that for the purposes of this section antimicrobials
mean antibiotics, which are antibacterial in their action.
2. Can POM-VPS veterinary medicinal products be advertised to owners
or keepers of horses?
No. Advertisements for POM-VPS products should only be aimed at
veterinary surgeons, pharmacists, SQP, other veterinary health care
professionals and professional keepers of animals.
3. Can brand names of POM-VPS medicines be used in educational
articles aimed at owners or keepers of horses?
No. However articles, intended to give a balanced and unbiased overview of
all treatment options are allowed, provided they are un-branded. The naming
of active substances in such articles is permitted. Please see FAQ No. 13
below
4. Can Press Releases be published on an existing or new anti-microbial
product using the brand name to professional keepers of animals?
No. The use of a brand name is considered to be promotional, so any
material published must contain only the name of the active substance(s).
5. What safeguards, if any, are in place to ensure that only the target
audience will have access to these publications?
The VMR require that advertisements of prescription only medicines must be
aimed at those who are entitled to prescribe and supply them. It is
understood that on occasion those who are not entitled to see such
advertisements may, but if the magazine is not targeting them specifically, no
offence is committed.
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January 2014
7. Can I advertise veterinary medicinal products at trade shows,
conferences or fairs?
Care should be taken when organising promotional material at these events to
identify the audience attending, so that advertising material does not fall foul of
the rules on advertising. Fliers, banners, low value gifts, such as pens, mugs
etc. should comply with the advertising requirements.
Retail suppliers
8. Can I offer promotions such as buy one get one free or rewards for
purchases of medicines available from veterinary surgeons, pharmacists
or SQPs?
Any promotion that attempts to influence the decision of the prescribing
professional, especially for financial gain, is inappropriate.
Medicine selection and supply must be based on clinical suitability for the
animals and treatment concerned.
Low value gifts such as mugs, pens, calendars, small goods are permitted but
they must not influence the animals treatment. Any discounts and other types
of promotions must not drive the inappropriate prescription or supply of a
veterinary medicinal product.
9. Can I display posters for prescription products in my waiting room/retail
area?
Advertising literature for any product categorised as POM-V or POM-VPS may
not be displayed in public areas, including waiting areas.
10. Is it acceptable to store prescription products within view of a public
area?
We do not consider the storage of veterinary medicines within view of a public
area (eg on display behind a retail counter) to be an advert as no one product is
being promoted. This practice is acceptable as long as no attempt is made to
make any product(s) more prominent than the others.
11. How do I promote my prices without advertising the products?
A price list is not considered to be advertising material, providing that it does
not feature any product(s) more prominently than others. Price lists may be
displayed in public areas such as waiting rooms. Font size/colour/formatting
etc. should be consistent so that no particular product(s) is highlighted.
Price lists should consist of a list of all products belonging to a particular
category, e.g. all wormers or all vaccines. It is not acceptable to have a list of
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January 2014
one product from several different categories, e.g. one vaccine, one horse
wormer, one sheep wormer etc.
12. Can I send my clients vaccination reminder cards produced by the
manufacturer of my preferred product?
Any document that features information about a single product is deemed to be
advertising. It is acceptable to send a complimentary vaccination reminder card
to a client which features a company strapline:
i.e. Brought to you by (company name), makers of (product brand name).
13. Can I mention a specific prescription product name in an animal health
information note to make clients aware of, e.g. the dangers of lungworm
infections in dogs, if I send it exclusively to existing clients that own
dogs?
Educational articles that seek to inform and educate may feature the active
substance of veterinary medicines provided they are unbiased and not intended
to promote a single product.
14. Can I send literature that features a company strapline to clients?
Yes, the following strapline is acceptable:
Brought to you by (company name), makers of (product brand name).
Online retail suppliers
15. I operate an online retail outlet for veterinary medicines - how do I feature
the prescription products I supply without advertising them?
You may feature prescription medicines on your website in a price list format.
This may include a small photo as long as all photos are the same size and all
prescription products are given equal prominence. Font size/colour/formatting
etc. should be consistent so that no particular product(s) is highlighted (See
also question 7 above).
Online features such as:
Featured products
Best sellers
People who bought this product also bought
'We sell the following products.'
which relate to prescription products are not permitted.
The homepage of a website should not display prescription medicines. We
consider the homepage of a website to equate to the waiting room of a
Veterinary Practice Premises or SQP Retailer premises.
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January 2014
16. Can I use product trade names in sponsored adverts on search engines?
Yes, 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 the VMD recognises that search engines are a valuable tool to
enable consumers to shop online efficiently, therefore the VMD considers it
acceptable for online retailers to use these adverts to direct customers to their
sites in response to product specific search terms. However the use of non-
specific terms to advertise veterinary medicines is not acceptable.
For example: if a customer uses a search engine to find a particular product,
an online retailer may name that product and the price in the advert to direct
the customer to their site. However non-specific search terms such as dog
medicine or cat medicine should not be used to bring up adverts for specific
products.
Marketing Authorisation Holders (MAHs)
The VMD has worked closely with the National Office of Animal Health (NOAH) to
create a Code of Practice for the promotion of veterinary medicines; while only
NOAH members are accountable to the provision of the code the VMD encourages
all MAHs to consider the code when undertaking promotional work. The latest
version of the code can be found here: http://www.noah.co.uk/issues/code.htm
17. As an MAH can I offer free entrances to conferences or hospitality to
retailers?
This is covered by Section 15 Sponsorship, gifts, hospitality of the NOAH
code and the accompanying guidance note 4: Provision of Gifts and
Inducements in Relation to Sales Promotion of Animal Medicines.
Such sponsorship or hospitality must not seek to drive the inappropriate
prescription or supply of a veterinary medicinal product. Any promotion that
attempts to influence the decision of the prescribing professional, especially for
financial gain, is inappropriate.
18. As an MAH can I promote cash discounts or rewards for purchasing a
specific product to animal keepers via retailers such as Veterinary
surgeons, Pharmacists and SQPs?
No, medicine selection and supply must be based on clinical suitability for the
animals and treatment concerned.
Low value gifts such as mugs, pens, calendars, small goods are permitted but
they must not influence the animals treatment. Any discounts and other types
of promotions must not drive the inappropriate prescription or supply of a
veterinary medicinal product.
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January 2014
19. What claims can I make in my advertising literature?
An advertisement can contain any factual claim about the product as long as it
is supported by the Summary of Product Characteristics (SPC).
It is an offence to advertise a veterinary medicinal product if the advertisement
is misleading or contains any medicinal claim that is not in the SPC.
20. Where can I publish my advertising literature?
Advertisements for POM-V products may only feature in publications aimed at
veterinary surgeons, pharmacists, veterinary nurses and professional keepers
of animals (this does not apply to advertisements to professional keepers of
animals for anti-microbial medicines which are prohibited).
Advertisements for POM-VPS products may only feature in publications aimed
at veterinary surgeons, pharmacists, SQPs, other veterinary health care
professionals and professional keepers of animals.
There are no restrictions placed on the advertising of NFA-VPS, AVM-GSL and
products marketed under the Exemptions for small pet animals in terms of the
target audience.
Wholesale Dealers Authorisation holders
21. I am a wholesaler who supplies human medicinal products for veterinary
use under the cascade - can I advertise authorised human medicinal
products to the veterinary sector?
You may send a price list detailing authorised human medicinal product(s) to a
veterinary surgeon but only when specifically requested by the veterinary
surgeon for use under the cascade.
The list must clearly state that the product(s) does not have a marketing
authorisation for veterinary use.
Veterinary Specials Authorisation (ManSa) holders
22. I am a specials manufacturer - can I name the specific products I
manufacture?
Manufacturers of specials may advertise the services they provide.
ManSa holders cannot promote the specific substances that are manufactured,
however types of dosage forms are acceptable i.e. capsules, syrups...etc.
ManSa holders may provide lists of active substances and formulations with
prices to veterinary surgeons but only on request.
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23. I am a specials manufacturer - can I supply samples of the products I
make to veterinary surgeons?
Manufacturers of specials are allowed to send placebo samples to veterinarians
enquiring about their services.