There has been much debate over the last couple of years over the issue of veterinary POM(V)s [prescription only medicines] being advertised on the internet, and over what the Veterinary Medicines Directorate (VMD) could and should do about it, given that advertising POM(V)s to the consumer is illegal under European Law - it is prohibited by the relevant European Directives controlling not just veterinary POMs, but also human POMs.

The problem the VMD has had to wrestle with is that if it stops UK veterinary medicines retailers from enabling POM(V)s to be found on the likes of Google then purchasers of these products using Google have an incentive to buy the products from overseas, where VMD has no jurisdiction. In fact, this year even members of the VMD's Accredited Internet Retailer Scheme have been placing ads for POM(V)s on Google and perhaps inevitably there has been a recent change in its policy.


Within the last month VMD has quietly updated VMD Guidance Note No. 4, Controls on Advertising, the Guidance Note it issues to tell people how it expects them to comply with the legislation on advertising medicines. Click here if you wish to download a copy from the VMD site.

There is a notable change which is at page 5:

Advertising of products on the internet


14. Veterinary prescription products can feature in sponsored/paid for adverts on internet search engines. These searches are carried out by people who have been issued with a prescription for the product by a veterinary surgeon, which results in a list of retailers who can supply that product."


This statement is true enough: Searches are carried out by people who have been issued with a prescription for a product by a vet. However, searches are also carried out by people who have previously purchased a POM(V) from a vet who don't have prescriptions, and by people who haven't previously purchased POM(V)s from vets but are aware of them, perhaps because they've been told about them by somebody else who has purchased them, perhaps face to face, in an internet chat-room or on a social media site.

Just above point 14 (the new statement) VMD GN4 says:

"13. The advertising controls within the VMR apply to promotional material placed on the internet."

and earlier in the document you have the advice that has been there for years:

"3. The VMD considers an advertisement to be any activity that is aimed or designed to promote the sale, supply or use of a veterinary medicine regardless of the form or media used.
4. Some examples of types of promotional advertisements are:
• mail shot e-mails to customers;

• postal flyers;

• website banners or ‘pop-ups’;

• sponsored banners on Internet search engines;

• text providing information about animal illnesses that specifically promotes the use of particular veterinary medicinal products.


7. It is an offence under the VMR for a product available on prescription to be advertised to the general public. "

"10. Advertising information aimed at the general public may not include the brand name of a POM-V/POM-VPS product in relation to treatment but it 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]’. "





Looking at the guidance as it stands then we would predict that there will still be considerable debate on VMD Guidance Note 4 as internet retailers are going to have to reconcile the new statement with the others that appear contradictory: For example, the fact that sponsored banners on internet search engines are defined as promotional adverts but searches on internet search engines, paid for or not, by name of product are acceptable IN sponsored paid for adverts, whatever that may mean.

So VMD GN4 looks a bit more complex than it used to: If you wanted to keep it simple - when is an advert for a POM(V) not an advert? When it's a search.

But that assumption that people searching for POM(V)s on the internet have prescriptions is quite a big assumption....