Background
This ruling forms part of a wider piece of work on prescription-only medicines (POMs) used for weight loss. See also related rulings published on 9 July 2025, 17 December 2025, 11 February 2026, 18 February 2026, 8 April 2026, 27 May 2026, 24 June 2026 and 9 July 2026.
Ad description
Two paid-for Facebook ads for Bolt Pharmacy.
a. The first Facebook ad, seen on 16 February 2026, featured the caption, “Affordable Weight Loss Starts Here … See more”. The ad featured an image of Bolt pharmacy branded packaging next to pound coins and text stating, “Price drop alert. We’ve cut the cost of our weight loss solution”.
When clicked on, the “See more” in the caption expanded to further text, which stated, “Getting real medical weight loss treatments shouldn’t cost a fortune. Bolt Pharmacy offers the lowest UK prices on prescription treatments, with licensed prescribers and convenient online ordering. Simple, safe, and affordable”.
b. The second Facebook ad, seen on 3 March 2026, featured the same text in the caption as ad (a). An image in the ad featured the same Bolt pharmacy branded packaging as ad (a) and text stating, “SYSTEM CRASHED PRICING ERROR. Our system is still showing LAST YEAR’S WEIGHT LOSS PRICES. Take the 2-Minute Quiz Before It’s Fixed”.
Issue
The ASA challenged whether the ads breached the Code because they promoted POMs to the public.
Response
Bolt Healthcare Ltd t/a Bolt Pharmacy said one version of the ad referred to “prescription treatments”. They accepted that wording was unsuitable for a public-facing ad, and withdrew that version of the ad. They said they would carry out a wider review of ad copy to ensure compliance across their advertising.
They further accepted that POMs should not be promoted to the public through user journeys. They said they were updating their user journeys so that users would complete a clinical consultation before any POMs were shown.
They said they were committed to ensuring their advertising and user journeys complied with the rules.
Assessment
Upheld
The CAP Code stated that POMs or prescription-only medical treatments must not be advertised to the public.
The ASA acknowledged that the ads did not name a specific POM active ingredient or POM. However, we considered the reference to “prescription treatments” in ad (a) promoted POMs to the public.
Furthermore, we understood that Chapter seven of the Medicines and Healthcare products Regulatory Agency’s (MHRA) ‘The Blue Guide’ stated that a website homepage should focus on medical conditions and the service the website provided, and not include any reference to named POMs. It said that links and navigation aids may be given for particular conditions and diseases but not be specific to POMs. The guidance said that further pages about the condition, which consumers chose to access, may contain non-promotional information on specific medicines provided that was presented in the context of a fair overview of the treatment options.
We understood that landing pages from paid-for ads on social media were akin to a homepage, for the purposes of The Blue Guide. Ad (a) linked through to an age gate. We considered the age gate functioned as a means of asking the user to confirm that they were old enough to use the site’s services before continuing to the landing page. Ad (b) linked through to an initial webpage with two options, “Go to weight loss treatments” and “I’m interested in switching”. We considered that this initial page was not the landing page, rather a filtering page that directed consumers to a landing page akin to a homepage. Both selections resulted in consumers being shown the same landing page.
The landing pages accessed from both ads included comparisons between “Wegovy” and “Mounjaro”, alongside images of Wegovy and Mounjaro branded injection pens. We understood Wegovy (semaglutide) and Mounjaro (tirzepatide) were classed as POMs.
We considered that consumers who had clicked through to the landing pages were actively presented with POMs, as opposed to information about particular conditions and diseases. We considered that because the landing pages linked to from the ads, via a filtering page or an age gate, referenced POMs, the ads therefore promoted POMs to the public.
We sought advice from the MHRA. They expressed concern that an advertisement was likely to lead to the use of a POM in circumstances where the consumer had been invited to follow a discrete path which guided them, even if the promotional message was spread across a number of pages, to these weight loss medicines. They also expressed concern that the ads did not appear to support the rational use of a medicinal product.
For those reasons, we considered the ads promoted POMs to the public and concluded that they breached the Code.
The ads breached CAP Code (Edition 12) rule 12.12 (Medicines, medical devices, health-related products and beauty products).
Action
The ads must not appear again in the form complained of. We told Bolt Healthcare Ltd t/a Bolt Pharmacy not to promote POMs to the public in future.
