The UK Medicines and Healthcare products Regulatory Agency has published new draft guidance for companies operating consumer websites, to help them promote their services without promoting specific prescription-only medicines, which would be in breach of the UK Advertising Regulations.

The guidance covers all websites registered in the UK or aimed at UK consumers (not healthcare professionals), run by companies and organisations which do not hold marketing authorisations for medicines but provide services that may lead to the prescription and/or supply of POMs. Examples of these include diagnosis and treatment services for erectile dysfunction or treatments for lines and wrinkles.

In general, says the guidance, online clinics or pharmacies may promote the service they provide and give information on a certain condition and its management, which may include a balanced overview of the range of therapeutic options available. However, this should not draw attention to POMs since this is likely to encourage consumers to request a particular treatment, which would be in breach of the Regulations. The appropriate management for a condition in an individual patient is for the prescriber and patient jointly to consider and this may include a number of medical factors as well as a range of therapeutic options, it adds.

Tips for website content
The MHRA’s tips for ensuring that website content does not promote medicines include that:
- information on a condition or disease may be provided on websites, but information relating to POMs should be presented in the context of a balanced overview of all treatment options and relevant disease information;
- the home page should focus on medical conditions and the service the website provides, avoiding direct reference to named POMs. Links and navigation aids may be given for particular conditions and diseases but not to specific POMs. Further pages about the condition may contain information on specific medicines, provided this is presented in the context of an overview of the treatment options. It should be clear that the consumer is being offered a medical consultation and that this may or may not lead to the customer being provided with a prescription;
- information on the cost of specific POM products should only be provided as part of the prescribing process or after a prescription has been issued. Indicative costs of a consultation and course of treatment may be given;
- icons or other features encouraging the purchase of POMs for example, “Buy Now”, “Buy XXX” etc. should not be used on websites, as it invites consumers to purchase POMs and is intended to promote sales. Icons may be used to encourage people to undertake a medical consultation;
- promotional claims should not be made for specific POMs, as this is likely to encourage their purchase. All information about medicines should be balanced and factual, for example “XXX is used to treat …” rather than “XXX, the best/fastest/strongest/etc treatment for ….” Suitable sources of non-promotional material may include the UK website of the company marketing the product or the patient information leaflet. Unlicensed medicines should not be mentioned.

The MHRA is issuing the guidance as a draft and welcomes comments from users on how helpful it is and on additional areas that should be covered. Comments and suggestions should be sent to advertising@mhra.gsi.gov.uk by 30 September.