Advertising non-medicinal veterinary products
Explainer on 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:
- is ‘medicinal by presentation’, this means, presented as having a medicinal purpose or properties to treat or prevent disease
- is ‘medicinal by function’ - it contains a substance with proven medicinal effects for treating or preventing disease
Understanding ‘medicinal by presentation’
A product may be medicinal by presentation if you present it as having a beneficial effect or improvement on an animal’s health problems.
What prevention means
Prevention covers stopping harm to an animal’s health. For example, a vaccine would be considered a preventative medicine.
Likewise, a product which has the function of destroying parasites that may cause medical conditions would be considered a preventative medicine.
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.
Feed regulations do allow declarations related to nutritional imbalances. Provided these declarations are in line with the appropriate feed legislation, we would not consider them to be medicinal claims relating to disease.
What restore, correct or modify means
Restoring covers bringing back normal function in any body system that is not working properly in an animal.
Correcting covers products used to address an imbalance or dysfunction in an animal’s health.
Modifying covers any effect that changes how an animal functions. These are usually enhancement claims which go beyond normal or natural health.
If you claim use of your product will result in the animal’s systems or, anatomy, being ‘notably improved’, your product may be considered medicinal. If you claim use of your product will result in the animal being ‘better than an animal with a specific condition’, your product may also be considered medicinal.
However, the VMD recognises that this guidance should also be read in conjunction with existing feed regulations. The aim of this guidance is to be used alongside existing feed regulations. We understand that certain feed additives have been authorised to improve an animal’s health and wellbeing and provided these products are being labelled and used in accordance with their authorisation, we would not consider them to be 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 for treating or preventing disease.
This includes:
- active substances found in authorised veterinary medicines
- biocidal substances used inside an animal or on open wounds
A published list of substances that we considered to be medicinal by function is available to view at Substances recognised as medicinal by function in veterinary medicines - GOV.UK. You should ensure that any ingredient will not make your product medicinal if it does not have a marketing authorisation, as detailed in this guidance. If you have a concern, then you may contact the Enforcement team at enforcement@vmd.gov.uk.
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 in any marketing material or labelling for a non-medicinal product.
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, for 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.
Good nutritional or husbandry advice would not be considered medicinal under this guidance, for example a horse with low fibre intake receiving a high fibre diet/feed.
If your product’s nutritional formulation supports normal physiological function, manages recognised nutritional risk factors in healthy animals or is formulated for the support of specific life stages, breed characteristics and support of recognised nutritional sensitivities in accordance with feed legislation, it is unlikely to be considered to be medicinal.
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
Use of scientific substantiation to communicate nutritional benefits in a factual and responsible manner is permissible provided this does not imply a medicinal intent.
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’
- ‘Diarrhoea remedy’
- ‘Prevents heart disease
- ‘The herbal alternative to phenylbutazone (Bute)’
- ‘Reduces pain’
Product names
We would not expect to see a product name that would imply a specific medicinal effect in non-authorised products, such as “Diarrgone for Cats”. Misspelling, partial spelling or phonetic spelling of a disease in a product name may still be considered a medicinal claim if the disease can be easily 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
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”’
We would not expect or ask companies to monitor and act against such reviews on third party sites. However, such reviews should not be used by a company to promote a product.
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’ 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 and includes commonly used words and phrases we have seen previously and acted to remove. There may be further words or phrases that would constitute a medicinal meaning, if so then these should also be avoided. This list is reviewed regularly and amended as necessary.
Rules for testimonials and reviews
Testimonials
If you use testimonials that contain medicinal claims, those claims are treated as your company’s claims.
Press releases, adverts and advertorials
If a press release presents a product with medicinal claims, both the company providing it and the party publishing it may be responsible for breaching the regulations. However, we would look to take a proportionate approach in line with our published enforcement policy.
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 host and or control your customer review system, for example, you can remove or prioritise reviews, the content of those reviews is your company’s responsibility.
If you have a public review system on your site, we expect you to ensure that those reviews do not include medicinal claims for non-medicinal products. If they do, then we would expect these to be removed.
Independent reviews
Reviews are only exempt if they’re published on a third-party controlled site, such as some independent review sites, like Google reviews or Trustpilot.
Providing educational materials
You may wish to provide advice on animal care. Any advice given must follow the advertising rules. If this advice relates to health conditions, their causes or effects, it must be separate from marketing material for non-medicinal products.
What educational material must not include
- reference to products that are not authorised veterinary medicines for treating that disease or symptom
- images, links to product pages or directions to your products
- reference to ingredients in your products that are not authorised veterinary medicines for treating disease
- links to third-party sources that are prohibited by the above rules
- data from studies relating to products that are not authorised veterinary medicines for treating disease
Rules for importing products
You are responsible for ensuring imported products comply with these regulations.
If an imported veterinary product has medicinal claims on the label or contains a medicinal substance, it may be considered an illegally imported veterinary medicine. It is the importers responsibility to ensure products are legal to import or we may be required to take enforcement action which may 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 for 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 – complementary, compound and supplements
The VMD does not regulate non-medicinal feed products. However, Trading Standards (TS) or the Food Standards Agency (FSA) may regulate them.
What you must not claim
Do not present feed products as having antibiotic, anti-fungal, antiviral, antibacterial or anti-parasitic effects.
Feed ingredients
Having an ingredient on an officially recognised ingredient list or feed material register may not exempt it from being classed as medicinal by function.
You must ensure that the ingredients are included in line with the requirements of the relevant official ingredient list or feed materials register and that the product is manufactured and labelled in accordance with its feed authorisation.
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 assimilated Commission Regulation (EU) 2020/354.
You must use the exact wording from the regulation. You must not add extra information about the condition.
For example, if the approved indication is ‘Support of energy metabolism and of the muscle function in the case of rhabdomyolysis’, you must not add terms such as ‘tying up’.
If the VMD has any concern with a product that has been authorised/registered in this way, they will be discussed with the FSA to identify whether the wording breaches any feed regulations in place. In cases where a breach is identified action will be taken by the appropriate agency with responsibility, FSA who would be responsible for enforcing under their regulations, or it may be for the VMD to act under the VMR.
Specific welfare exceptions
The VMD recognises two welfare concerns in UK horses and allows the following product indications:
- Feed products indicated as suitable for horses and ponies prone to laminitis
- Feed products indicated as suitable for horses and ponies prone to gastric ulcers
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 kill or treat 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 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.
A registered biocide may identify the specific microbes it’s effective against but must not reference the diseases those microbes cause.
Competitive exclusion products
These products use probiotic principles to suppress pathogenic bacteria in the environment. You must not present them as having any medicinal effect on the animal.
Behavioural products - calmers
These products usually contain either:
- synthetic pheromones that resemble those released by mothers to calm offspring
- feed ingredients with calming effects
You must not make medicinal claims for these products.
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.