Advertising non-medicinal veterinary products
Explainer for the rules for advertising products used in, on or near animals that are not licensed veterinary medicines.
Who this guidance is for
You must follow these rules if you make, advertise, sell or supply products intended for use in, on, or near, animals in the UK.
This includes products such as:
- feeds and supplements
- topical hygiene products
- bedding and housing products
- behavioural products (calmers)
Even if you think your product is not a medicine, you must read and follow this guidance before advertising, selling or supplying it in the UK.
What counts as a veterinary medicine
The Veterinary Medicines Regulations 2013 (as amended) (VMR) define a Veterinary Medicine as:
- any substance or combination of substances presented as having properties for treating or preventing disease in animals; or
- any substance or combination of substances that may be used in, or administered to, animals with a view either to restoring, correcting or modifying physiological functions by exerting a pharmacological, immunological or metabolic action, or to making a medical diagnosis; or
- any substance or combination of substances that may be used for the purpose of euthanising an animal.
Products that need authorisation
Your product needs authorisation as a veterinary medicine before you can sell it if it either:
- is ‘medicinal by presentation’ - you present it as having a medicinal purpose or properties
- is ‘medicinal by function’ - it contains substances with proven medicinal effects
Understanding ‘medicinal by presentation’
A product is medicinal by presentation if you present it as having a beneficial effect on an animal’s health problems.
What prevention means
Prevention covers stopping harm to an animal’s health. This includes destroying parasites that may cause medical conditions.
For example, products that kill fleas on animals are classified as medicines because fleas can cause flea allergic dermatitis.
What disease means
Disease covers a broad range of conditions, including those caused by:
- bacterial, viral or parasitic infections
- systemic dysfunctions
- deficiencies of essential substances
We use the term ‘adverse health condition’ to describe anything wrong with an animal’s health. This includes injuries that pose a significant risk to wellbeing or need more than basic care.
What restore, correct or modify means
Restoring covers bringing back normal function in any body system that is not working properly in an animal.
Example: A product that restores joint function in dogs that can barely walk would be medicinal.
Correcting covers products used to address any deficiency or dysfunction in an animal, such as:
- nutritional deficiencies
- hormone imbalances
- allergic reactions
- digestive problems
Modifying covers any effect that changes how an animal functions. These are usually enhancement claims such as ‘boosting’, ‘better’, ‘promotes’ or ‘stronger’.
If you claim use of your product will result in the animal’s systems, anatomy, or health being ‘better than normal’, your product is medicinal. If you claim use of your product will result in the animal being ‘better than an animal with a specific condition’, your product is also medicinal.
Understanding ‘medicinal by function’
A product is medicinal by function if it contains a substance that the Veterinary Medicines Directorate (VMD) recognises as having a proven medicinal effect.
This includes:
- active substances found in authorised veterinary medicines
- biocidal substances used inside an animal or on open wounds
- substances on the VMD’s Medicinal by Function Substance List - link new version
Any product that is medicinal by function must be authorised as a veterinary medicine before you can sell it in the UK.
Substances classified as medicinal by function are not banned. Products containing them must be authorised as veterinary medicines. For example, an authorised CBD-based veterinary medicine would be legal. Any other CBD product for animals would be an illegal veterinary medicine.
Herbal and ‘natural’ products
Herbal products, nutraceuticals and ‘natural’ products follow the same rules as other products. A natural origin provides no exemption.
Traditional medicinal uses
Do not reference the traditional use of a substance for medicinal purposes.
A substance’s reputation for medicinal properties does not exempt you from these rules.
Examples of prohibited claims:
- ‘Everybody knows that…’
- ‘It’s a fact it can…’
- ‘Used for 4000 years to treat…’
You must not reference ‘Traditional Medicine’ as this is explicitly a medicinal claim.
What you can claim for non-medicinal products
Health maintenance
Non-medicinal veterinary products may only be presented for maintaining health in healthy animals.
Health maintenance means providing the materials, hygiene and environment a healthy animal needs to maintain its own health.
Example: A joint supplement providing ‘building blocks’ to support a horse’s joints during competition or intense exercise.
Health maintenance is continuing normal health through non-interventional care.
The word ‘support’ is often used as an alternative to ‘maintain’, and follows the same rules.
What health maintenance does not mean
Health maintenance does not include claims:
- to prevent a health problem developing
- ‘against’ anything or to prevent harm, for example, ‘maintains your dog against allergy symptoms’
- that alter an animal’s body, for example, ‘promotes a healthy immune system’
- that present your product as a solution to a problem
- using ‘doom’ narratives, for example, ‘8 out of 10 horses will get this disease’
- to enhance wellbeing
- to address anything wrong with an animal’s health
- about preventing death or extending life
- using phrases like ‘prevention is better than cure’, even as a company philosophy statement.
What counts as advertising
Advertising includes any activity or content used to communicate information about a product to potential customers.
This includes:
- a company representative at a trade stand talking about the product
- signage on that stand
- the website behind a QR code on the signage
- product pages on websites
- downloadable case studies
- links to scientific journal articles
- social media posts
Types of medicinal claims you must avoid
Direct claims
Do not make specific or implied claims for a purpose or effect that would make the product a medicine.
Examples of prohibited claims:
- ‘Boosts the immune system’
- ‘Balances the digestive system’
- ‘Diarrhoea remedy’
- ‘Promotes joint function’
- ‘The herbal alternative to Bute’
- ‘Ideal for grumpy tummies’
- ‘Reduces brain aging’
Product names
Do not use product names that imply a medicinal purpose or effect.
Examples of prohibited names:
- ‘Medisnax Dog Chews’
- ‘Painaid Tincture’
- ‘Diarrgone for Cats’
- ‘FauxBute’
Misspelling, partial spelling or phonetic spelling of a disease in a product name is still a medicinal claim if the disease can be identified. The same applies to acronyms.
Research and studies
Do not present or reference research data that associates your product with a medicinal purpose or effect.
Example of a prohibited claim:
‘Fortified with Chemical X. Jane Doe et al. The effects of Chemical X on the allergic inflammatory response in midge-sensitive horses. Vet J 1999’
If a product has proven medicinal effects, it must be authorised as a veterinary medicine before you can sell it.
When you present or reference a study, the entire study becomes advertising material. This includes:
- background observations
- how animals were selected
- the author’s speculation on results
You cannot avoid this rule by sending studies privately. For example, saying ‘The VMD told us we can’t publish our study, but leave your email and I’ll send it to you’ still counts as advertising.
Third-party claims
Do not reproduce or reference claims from third parties that present your product as having medicinal properties.
Example of a prohibited claim:
‘Another great review of our product: “Doggy Daycare blue gel worked wonders on my Fido’s atopic dermatitis”’
Images
Do not use images that imply a medicinal effect or purpose. This includes before and after images where the animal has a visible health condition or injury that needs veterinary treatment.
Ambiguous claims
Saying a product ‘may help’ does not protect you from making an unauthorised medicinal claim.
Presenting a product that ‘may treat kennel cough’ is the same as presenting a product that ‘treats kennel cough’. The medicinal purpose is clear.
Disclaimers
Disclaimers do not protect you from presenting a product as having medicinal properties.
Medicinal words and phrases
Many words and phrases have established medicinal meanings when used for veterinary products. The VMD has a list of medicinal words and phrases you can refer to.
This list is not exhaustive so should be used as a guide. There may be further words or phrases that would constitute a medicinal meaning, if so then these would also not be allowed to be used.
Rules for testimonials and reviews
Testimonials
If you use testimonials that contain medicinal claims, those claims are treated as your company’s claims.
Third-party content
Claims made by third parties, such as magazine reviews or articles, are treated as your company’s claims if the third party has a connection to you through:
- solicitation
- endorsement
- sponsorship
- funding
- provision of samples for review
Press releases
If a press release presents a product with medicinal claims, both the company providing it and the party publishing it are responsible for breaching the regulations.
Veterinary endorsement
Endorsement by a veterinary professional does not make a product medicinal by presentation. However, it must still follow these rules.
Veterinary professionals and experts are not exempt from making unauthorised medicinal claims.
Customer reviews
If you control your customer review system (for example, you can remove or prioritise reviews), the content of those reviews is your company’s responsibility.
Any difficulties in monitoring reviews are your responsibility when you provide the facility for customers to make them.
Independent reviews
Reviews are only exempt if they’re entirely under third-party control, such as some independent review sites.
You must not:
- have the ability to suppress negative reviews
- selectively reproduce reviews that make medicinal claims
Such actions mean the reviews are considered advertising material and subject to regulation.
Providing educational materials
You may wish to provide advice on animal care. If this advice relates to health conditions, their causes or effects, it must be completely separate from marketing material for non-medicinal products. Remember, any activity used to encourage the use, sale or supply of a product counts as advertising.
What educational material must not include
Do not:
- refer to products that are not authorised veterinary medicines for treating that disease or symptom
- include images, links to product pages or directions to your products
- refer to ingredients in your products that are not authorised veterinary medicines for treating that disease or symptom
- provide links to third-party sources that are prohibited by the above rules
- include data from studies relating to products that are not authorised veterinary medicines for treating that disease or symptom.
Rules for importing products
You are responsible for ensuring imported products comply with these regulations.
If an imported product has medicinal claims on the label, it’s an illegally imported veterinary medicine. You must ensure imported products are legally labelled or we may be required to take enforcement action which could include seizing the products.
If you import products for retail, their presentation must comply with this guidance. Other countries may have different approaches to product presentations, so reproducing the manufacturer’s advertising may risk an unauthorised medicinal claim.
Find out more on Import a medicine for veterinary use into the UK - GOV.UK.
Exception for cascade products
The only exception is products imported under a VMD certificate by a registered wholesale dealer, pharmacist or vet for use under the prescribing cascade. These products must not be advertised.
Find out more about the cascade: prescribing unauthorised medicines.
Rules for specific product types
Feeds and supplements
The VMD does not regulate non-medicinal feed products. However, Trading Standards or the Food Standards Agency may regulate them.
What you must not claim
Do not:
- use philosophical quotes that imply a medicinal purpose for your feed product. For example, the phrase ‘Let food be thy medicine, and medicine thy food’
- present feed products as having antibiotic, anti-fungal, antiviral, antibacterial or anti-parasitic effects
Feed ingredients
Having an ingredient on a feed material register does not exempt it from being classed as medicinal by function.
Substantiating claims
Any evidence you publish to support feed product claims must not present the product as having medicinal properties.
Particular Nutritional Purposes
Some feeds can be used for ‘Particular Nutritional Purposes’ under retained Commission Regulation (EU) 2020/354.
You must use the exact wording from the regulation. You must not add extra information about the condition.
Example: If the approved indication is ‘Support of energy metabolism and of the muscle function in the case of rhabdomyolysis’, you must not add slang terms like ‘tying up’.
Specific welfare exceptions
The VMD recognises two welfare concerns in UK horses and allows the following product indications and provides the attached guidance:
- Feed products indicated as suitable for horses and ponies prone to laminitis - GOV.UK
- Feed products indicated as suitable for horses and ponies prone to gastric ulcers - GOV.UK
Topical hygiene products, repellents and parasiticides
Biocides are products that control harmful organisms through chemical or biological means. The Chemicals Regulation Directorate regulates these products.
Some biocidal products applied to animals are medicines and must be authorised before being sold.
Products that are medicines
The following products are considered medicines:
- products containing substances that kill insects or external parasites when applied to an animal
- products claiming to affect internal parasites; whether chemical or natural
- products claiming to treat or prevent disease caused by viral, bacterial or fungal infection
- products for use inside an animal that have a biocidal effect
- products for use on injuries that need veterinary intervention
Products that are not medicines
A product applied to animals that only contains a repellent is not a medicine, provided it only claims to repel external parasites.
A topical disinfectant applied to intact skin is not a medicine, provided you do not claim it treats or prevents disease.
Hygiene products for minor injuries
A topical hygiene product may be presented for cleaning:
- minor wounds
- minor cuts
- minor abrasions
- superficial tissue damage
You must not claim these products:
- prevent infections
- remove dead, damaged or infected tissue; debriding effects
Bedding and housing products
Products applied to animal bedding and housing must not be presented as having medicinal purposes or effects on animals.
Environmental hygiene products
Products for improving environmental hygiene must not be presented as reducing or preventing disease in animals. This includes references to disease symptoms.
A registered biocide may identify the specific microbes it’s effective against, but you must not reference the diseases those microbes cause.
Example: You can say ‘effective against canine coronavirus’ but not ‘effective against kennel cough virus’.
Competitive exclusion products
These products use probiotic principles to suppress pathogenic bacteria in the environment. You must not present them as having any effect on the animal, such as reducing mortality rates or symptoms.
Behavioural products - calmers
These products usually contain either:
- synthetic pheromones that resemble those released by mothers to calm offspring
- herbal products with calming effects
You must not make medicinal claims for these products.
What you can claim
Restrict claims to maintaining calmness in healthy animals.
What you must not claim
Do not reference:
- pathological behaviour
- psychological conditions such as separation anxiety
- changes to an animal’s brain chemistry
- sedatives or sedative effects; sedatives are medicines
Further help
For guidance on placing a veterinary medicine on the market, see legal requirements for placing a veterinary medicine on the market.
For guidance on advertising authorised veterinary medicines, see advertise veterinary medicines legally.
For guidance on animal feeds and their advertising, contact:
- your local Trading Standards Office
- the Food Standards Agency
For guidance on biocides, contact the Chemicals Regulation Directorate.