Background

This ruling forms part of a wider piece of work on prescription-only medicines (POMs) used for weight loss, identified for investigation following intelligence gathered by the ASA. See also related rulings published between 9 July 2025 and 2 September 2026.

 

Summary of council decision:

Two issues were investigated, both of which were Upheld.

Ad description

Two paid-for Meta ads and a website for Pharmacy Online:

a. The first paid-for Meta ad, seen on 2 June 2026, featured the text “Your GP said eat less, move more. You did. It worked for three months. Then it stopped. That is not a willpower problem. That is your hormones fighting back. For years, the clinical answer to that has come in the form of a weekly injection. And it works. But for a lot of people, the needle is the thing standing in the way. That is about to change. The same medication. The same mechanism. But a tablet, once a day, which means no needle and no fridge. The oral version is coming to the UK this summer, and Pharmacy Online will be among the first GPhC-registered pharmacies to offer it […] Register your interest now, and you will be the first to hear when it is available, along with exclusive early access pricing.”.

An accompanying graphic included the text “What changes when it’s a tablet. 1. No weekly injection. 2. No sharps bin in the bathroom. 3. No fridge planning before a holiday. 4. No sting. 5. Just water and a tablet. The oral weight management treatment is launching at Pharmacy Online […] Join the waitlist”.
 

b. The website homepage www.pharmacyonline.co.uk, seen on 26 June, featured a pop-up box with the text “THE WEGOVY PILL JUST GOT APPROVED IN THE UK”. Smaller text underneath stated, “Thousands of people across the UK have been waiting for this moment. Pre-order today to secure your place and save £30”. A text box accompanied by a button labelled “PRE-ORDER NOW” allowed users to submit their email address. A further button underneath the text “Not ready yet? Join the early access list” was labelled “JOIN THE EARLY ACCESS LIST”. Beside the text was an image of a hand holding a bottle labelled “wegovy 1.5mg (semaglutide) Tablets”.

c. The second paid-for Meta ad, seen on 26 June, featured the text “Your GP said eat less, move more. You did. It worked for three months. Then it stopped. That is not a willpower problem. That is your hormones fighting back. For years, the clinical answer to that has come in the form of a weekly injection. And it works. But for a lot of people, the needle is the thing standing in the way. That is about to change. The same medication. The same mechanism. But a tablet, once a day, which means no needle and no fridge. The oral version is coming to the UK this summer, and Pharmacy Online will be among the first GPhC-registered pharmacies to offer it […] Over 700,000 members, no subscription, no lock-in. Takes two minutes”.

An accompanying graphic depicted a billboard with an image of a hand holding a tablet alongside the text “The oral weight management tablet. Pre-order at Pharmacy Online”.

Issue

The ASA challenged whether:

1. ad (a) made medicinal claims for, and promoted, an unlicensed product; and

2. ads (b) and (c) breached the Code because they promoted POMs to the public.

Response

1. & 2. Express Healthcare Ltd t/a Pharmacy Online stated that the ads were produced by an external marketing agency, and had not been intended to breach the advertising rules.

In relation to ad (a), they acknowledged that the ad’s landing page included the statements “suppresses appetite and increases satiety”, “slows gastric emptying” and “helps regulate blood sugar”, and that the ASA was likely to understand those as medicinal claims. They stated the descriptions of the product had been drawn from a published trial for oral semaglutide. Other parts of the landing page were intended as editorial, information-led content about a treatment that was being widely trialled. They stated that at that stage, nothing was offered for sale; there was no pre-order or price payable, and the “register your interest” and “waitlist” options collected email addresses only. They said the landing page set out accurate information which was reliably sourced, and that oral semaglutide had been authorised by the Medicines and Healthcare products Regulatory Agency (MHRA) shortly after the ad had appeared. They had withdrawn the material as a precaution.

In relation to ad (b), Pharmacy Online said the pop up had been created and implemented by their external marketing agency, and that they were not aware it had been configured to appear immediately to every visitor on arrival at the website, rather than users who had chosen to look for the product on the website. They accepted the ad should not have appeared in that manner. They highlighted that no medicine could be supplied through their website without an assessment by a qualified prescriber, and that the “pre-order now” button, which collected only an email address, was informational to inform the customer of availability.

Pharmacy Online stated that ad (c) did not name or show any particular medicine and described a category of product, that being a once-daily oral weight-management tablet. They therefore considered it did not identify any specific medicine to the public. They stated that the landing page for ad (c) should not have been linked to through the ad, and had been intended to be reachable only through navigating through their website.

Pharmacy Online stated that all of the ads subject to investigation had been withdrawn as a precaution, and that they intended to conduct a full review of their advertising.

Assessment

The ASA understood that the Wegovy (semaglutide) tablet was the first oral GLP-1 tablet for weight management to be approved by the MHRA and was licensed as a POM on 11 June 2026. Prior to that date, no UK Marketing Authorisation was in place. After that date, the Wegovy tablet was classified as a POM.

1. Upheld


The CAP Code stated that medicinal claims may be made for a medicinal product that was authorised by the MHRA or under the auspices of the European Medicines Agency (EMA). A medicinal claim was a claim that a product or its constituent(s) could be used with a view to making a medical diagnosis or could treat or prevent disease, including an injury, ailment or adverse condition, whether of body or mind, in human beings. Medicines must have an authorisation from the MHRA or under the auspices of the EMA before they were marketed.

Ad (a) referenced difficulties people experienced when trying to lose weight, and stated “For years, the clinical answer to that has come in the form of a weekly injection” and “The same medication. The same mechanism. But a tablet, once a day, which means no needle”. The ASA considered consumers were likely to understand the ad to refer to existing weight-loss injections, all of which were POMs, and to be referring to a tablet version of those treatments. The ad incentivised consumers to “register your interest now” by offering “exclusive early access pricing”. We further considered that, by comparing the tablet to existing weight-loss injections and stating it was the “same medication” and an “oral weight management treatment”, the ad implied that the advertised tablet would have similar effects to existing prescription-only weight-loss injections and could help consumers lose weight. We therefore considered that the ad made medicinal claims that required the product to be authorised as a medicine.

The landing page for ad (a) included the headings “GLP-1 Pill coming soon” and “Wegovy Pill UK”, and invited users to register their interest in the tablet by submitting their email address. Text on the landing page described Wegovy as a new development in weight-loss treatment, stated “Wegovy in tablet form is designed to offer the same appetite-reducing and weight loss benefits as injectable GLP-1 medications” and compared the Wegovy tablet to the Wegovy injection, which was a POM. Text under the heading “How the Wegovy pill works” included the claims “suppresses appetite and increases satiety”, “slows gastric emptying” and “helps regulate blood sugar by increasing insulin secretion”. We therefore considered that the landing page for the ad promoted and made medicinal claims for the Wegovy tablet.

We understood that the Wegovy (semaglutide) tablet was the first oral GLP-1 tablet for weight management to be approved by the MHRA, and was licensed on 11 June. However, ad (a) was seen on 2 June, at a time where no oral GLP-1 tablets were authorised by the MHRA for weight management. Because of that, no medicinal claims could be made for the product.

We sought advice from the MHRA, who expressed concern that the ad promoted a medicinal product before a UK Marketing Authorisation was in place, which was not permitted.

Because ad (a) made medicinal claims for, and promoted, a product which was not authorised at the time the ad was seen, we concluded that it breached the Code.

On that point, ad (a) breached CAP Code (Edition 12) rules 12.1 and 12.11 (Medicines, medical devices, health-related products and beauty products).

2. Upheld


The CAP Code stated that POMs or prescription-only medical treatments must not be advertised to the public.

Ad (b) was a pop-up shown on the homepage of the Pharmacy Online website and featured the text “THE WEGOVY PILL JUST GOT APPROVED IN THE UK”. It included an image of a hand holding a bottle labelled “wegovy 1.5mg (semaglutide) tablets” and the text “Pre-order today to secure your place and save £30”. We understood that at the time the ad was seen the Wegovy (semaglutide) tablet had been licensed by the MHRA as a POM. The Pharmacy Online website was visible to the general public, and the ad made direct references to the Wegovy tablet and provided an invitation to pre-order it. We considered the ad therefore promoted a POM to the public in breach of the Code.

Ad (c) referenced difficulties experienced by individuals trying to lose weight, and stated “for years, the clinical answer to that has come in the form of a weekly injection”. We considered that consumers would understand the ad to be referring to injectable forms of weight-loss medication, all of which were POMs. The ad also stated “The same medication. The same mechanism. But a tablet, once a day, which means no needle and no fridge”, and included an image of a white circular pill alongside the text “The oral weight management tablet”. We considered that consumers would understand the image of a tablet combined with references to a “weight management” tablet that contained the same medication as injectable weight-loss POMs to mean that the advertised product was an oral version of a POM. We therefore considered the ad promoted a POM to the public.

We also understood that Chapter Seven of the MHRA’s 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. The landing page for ad (c) included images of boxes of Wegovy tablets, as well as comparisons between “Mounjaro”, the “Wegovy pen” and the “Wegovy pill”. We understood Mounjaro (tirzepatide) and Wegovy (semaglutide) were POMs.

We considered that consumers who had clicked through to the landing page were actively presented with POMs, as opposed to information about particular conditions and diseases. Because the landing page for ad (c) referenced POMs, it also promoted POMs to the public.

We sought advice from the MHRA. They expressed concern that the ads were likely to lead to the use of a POM.

For those reasons, we considered ads (b) and (c) promoted POMs to the public and concluded that they breached the Code.

On that point, ads (b) and (c) 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 investigated. We told Express Healthcare Ltd t/a Pharmacy Online not to make medicinal claims for, or promote, unlicensed products, or promote POMs to the public in future.

CAP Code (Edition 12)

12.1     12.11     12.12    


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