Manufacturers, distributors, and wholesalers cannot promote or advertise products imported under the Special Import Scheme. Jackie Catterall, Regional Managing Inspector (Northern Region) and Stacey Brown, Head of Supply Team, explain why.
Specially imported products are considered to be unauthorised veterinary medicines
These products do not hold a UK marketing authorisation, so they are classified as unauthorised medicines even though you have been granted permission to import and supply them in line with a valid certificate from us.
They may only be supplied against a veterinary prescription, which means that under Regulation 11 of the Veterinary Medicines Regulations (VMR), a supplier cannot advertise or promote this type of product.
What is considered advertising?
We have defined ‘advertising’ in our guidance, Advertise veterinary medicines legally, as any activity that is aimed or designed to promote the sale, supply or use of a veterinary medicine, whether for profit or not. This includes electronic advertising such as website banners and emails.
Manufacturers, distributors and wholesalers cannot advertise unauthorised veterinary medicines, either in writing or verbally. This includes use of:
- the product name, strength or size
- details of specific diseases or conditions for which the unauthorised products can be used
Types of promotional material considered to be advertising includes:
- price lists
- listings on any online ordering system, including ‘add to basket’ ordering
- mail shot emails and postal flyers to customers
- website adverts, banners or pop ups
- sponsored banners or search terms on internet search engines
- text providing information about animal illnesses that specifically promotes a particular unauthorised veterinary medicine
- presentations and other verbal communications
If you were to advertise these products, we would consider that to be a breach of the VMR and take appropriate action in accordance with our enforcement policy.
However, you can keep your veterinary surgeon customers informed by:
- answering questions regarding an unauthorised veterinary medicine
- making them aware that your company can supply unauthorised veterinary medicines in accordance with a Special Import Certificate, but not name the unauthorised products
- making them aware of any supply shortages of authorised veterinary medicines, but not name the alternative unauthorised veterinary medicine
Products can only be imported when there is no suitable authorised product available
The Special Import Scheme is an important tool to help ensure that vets can access the medicines they need to treat animals under their care when there is no authorised alternative product available.
The Scheme ensures that certificates are only issued in response to an exceptional clinical need where we have assessed that the product is required to protect animal health and welfare.
Do not abuse this system and put animals at unnecessary risk.
See our guidance on manufacturing and advertising these types of products legally
For more information on the Special Import Scheme see Import a medicine for veterinary use into the UK and for information on advertising those products, see Advertise veterinary medicines legally.
For latest information on supply issues of UK authorised veterinary medicines where no alternative product is known see Known supply problems with animal medicines
If you have specific questions on how this guidance applies to your products, email postmaster@vmd.gov.uk
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