Background
This ruling forms part of a wider piece of work on prescription-only medicines (POMs) used for weight loss, identified for investigation following complaints and intelligence gathered by the ASA. See also related rulings published between 9 July 2025 and 2 September 2026.
Ad description
A paid-for Google search ad for The Care Pharmacy, seen on 26 May 2026, featured an image of a grey, pen-shaped medical product, with a dosage window, next to a box that featured The Care Pharmacy’s branding.
Text stated “Weight Loss Solution | The Care Pharmacy” and “£149.99”.
Issue
The ASA challenged whether the ad breached the Code because it advertised a POM to the public.
Response
Care Pharmacy Bradford Ltd t/a The Care Pharmacy said that, on receipt of the ASA’s enquiries, they had instructed their agency to remove the ad across all platforms and channels. They said they had also removed references to named POMs from the consumer journey from other paid ads, including linked landing pages, and had removed imagery of injector pens and other assets that could be interpreted as promoting POMs.They also said they had amended the wording on age-gate and landing pages so that it focused on their clinical weight-management service rather than specific prescription-only treatments. They also said they were carrying out a wider audit of their paid advertising and associated webpages to ensure compliance with the CAP Code, MHRA guidance and ASA guidance, and would implement a stricter approval process in future.
Assessment
Upheld
The CAP Code (Edition 12) stated that POMs or prescription-only medical treatments must not be advertised to the public.
In assessing the likely consumer understanding of the ad, the ASA had regard to its consumer research “How people interpret ads relating to prescription-only weight-loss medicines” published in April 2026. The research provided useful evidence of how consumers interpreted references, imagery and other features in ads for weight-loss medicines, while recognising that each ad must be assessed on its overall presentation. Notably, the research found that images of weight-loss injector pens were a strong indicator to consumers that an ad was for a prescription-only weight-loss medicine.
In light of that research, we considered that many consumers would understand that the image in the ad was of a weight-loss injection pen, which we considered was a strong indicator to consumers that a weight-loss POM was being offered. We understood that all injectable forms of GLP-1 weight-loss medication were POMs.
We sought advice from the Medicines and Healthcare products Regulatory Agency (MHRA), who noted that an objective assessment of an ad is required to determine whether it can be regarded as designed to promote a medicinal product or products. Such an assessment requires consideration of a number of factors which may include the wording and imagery used in the ad and whether the material is designed to persuade, the likely effect on an average well-informed consumer, and the method by which it is distributed
Taking the above factors into account, we considered the imagery used in the ad promoted POMs to the public and breached the Code.
Furthermore, we understood that Chapter seven of the MHRA’s Blue Guide stated that a website home page 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 MHRA’s Blue Guide.
The ad linked to a landing page on the Care Pharma website via an intermediate page that required customers to confirm that they were over 18 years of age. The age-gate page included the text, “The Care Pharmacy is a weight loss clinic that offers clinically proven weight loss injections that make the hard part of losing weight easier”. As above, we understood that all injectable forms of weight-loss medication were POMs. We considered that the age gate functioned as a means of asking the user to confirm that they were old enough to use the site’s service before continuing to the landing page.
The landing page accessed via the age gate featured several named POMs including Mounjaro (tirzepatide), Wegovy (semaglutide), Nevolat (liraglutide) and Saxenda (liraglutide), alongside images of their respective injector pens, as well as Orlistat 120 mg capsules. We understood that all of those products were POMs.
We considered that consumers who clicked on the ad were directed, via the age gate, to a website landing page that referenced named POMs, rather than solely to information about weight-management services or treatment of a medical condition. We therefore considered that in providing a link to a landing page that featured named POMs, the paid-for Google search ad advertised POMs and also breached the Code on that basis.
We sought advice from the MHRA, who expressed concern that the 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 those weight-loss medicines.
For those reasons, we concluded that the ad breached the Code.
The ad breached CAP Code (Edition 12) rule 12.12 (Medicines, medical devices, health-related products and beauty products).
Action
The ad must not appear again in the form complained of. We told Care Pharmacy Bradford Ltd t/a The Care Pharmacy not to promote POMs to the public in future.
