Background
This Ruling forms part of a wider piece of work on prescription-only medicines (POMs) used for weight loss. The ads were identified for investigation following intelligence gathering by our Active Ad Monitoring system, which uses AI to proactively search for online ads that might break the rules. See also related rulings published on 9 July 2025, 17 December 2025 and 11 February 2026.
Ad description
An Instagram post, a TikTok post and a Facebook post promoting the weight-loss injection, Mounjaro:
a. The Instagram post, on the account @mymounjarojourneymrsat, posted on 8 December 2024 featured text which stated, “Share health and save: Give 15%, get 15% back Share your personalised code via email, message or link. You’ll receive a 15% off voucher whenever your code gets used. You can use your vouchers to enjoy savings of up to £30 per order. See terms and conditions”. Below was the code with a “Copy code” call to action button beneath. A caption on the post stated, “Medexpress wouldn’t price match as they’re [sic] said the other don’t include sharps bin. So ended up ordering from Zava, use code Below to get 15% off! I paid £122 for 5mg! REF7DGKYW4 #mounjaroweightloss #mounjaro […] #mounjaroweightlossjourney”.
b. The TikTok post on the account @paigeriley6, seen on 2 February 2025, featured an image of a screenshot from a mobile phone. Overlaid text stated, “ZAVA promo code for MJ” with an in-love face emoji. Text in the image stated, “Share health and save: Give 25%, get 25% back […] You can use your vouchers to enjoy savings of up to £40 per order. See terms and conditions”. Below was the code REFCBF9TJ8 and “Copy code” call to action button beneath. A caption on the post stated “ZAVA promo code for MJ #mounjaro […] #injections #weightloss #weightlossjourney #promocode #zava # weightlossjabs #wrightlosspen [sic]”.
c. An anonymous post on the Lipoedema Information UK Public Group Facebook page, dated 27 January 2025, stated, “Hey, just started my mounjaro journey and I have a 25% code if anyone would like it, It’s for Zavamed.com. There’s no better gift than the gift of good health. Use my code and you’ll get 25% off your first order at ZAVA: REFPSK6ETG Maximum discount value: £40”.
Issue
The ASA challenged whether the ads breached the Code because they promoted prescription-only medicines (POMs) to the public.
Response
Health Bridge Ltd t/a Zava said they had no commercial relationship with mymounjarojourneymrsat, or the anonymous poster in the Facebook group “Lipoedema Information UK”. They said any information those social media accounts provided about their services was outside their control and was not the result of affiliate relationships or commercial arrangements.
Zava said they did not run an affiliate scheme and, when contacted by social media users seeking commercial sponsorship, their policy was not to engage.
They said their discounts and referral codes applied to all their services and not just POMs,. They said there was no minimum spend requirement under their referral scheme, so they did not inadvertently encourage to choose higher-priced items, such as weight-loss POMs. Nevertheless, they had reviewed their materials to ensure no discounts or referral codes were targeted at POMs and that consumers understood they were requesting a consultation rather than purchasing medication.
@mymounjarojourneymrsat said they did not benefit from the discount codes because they did not make another purchase from Zava. They said they no longer posted discount codes.
@paigeriley6 and the anonymous Facebook user who posted ad (c) did not respond to our enquiries.
Assessment
The ASA was concerned by @paigeriley6 and the anonymous Facebook user’s lack of response and apparent disregard for the Code, which was a breach of CAP Code (Edition 12) rule 1.7 (Unreasonable delay). We reminded them of their responsibility to provide a response to our enquiries and told them to do so in the future.
Upheld
We understood that Zava, an online pharmacy selling weight-loss medication including prescription-only medicines (POMs), operated a ‘refer a friend’ scheme. Under the terms of that scheme, existing customers were given a unique discount code that they could share with friends. If the code was used by new customers to obtain a discount when placing their first order, the person who shared the code was entitled to a discount on their next order with Zava.
We understood that the posts were made from public accounts on Instagram, TikTok and Facebook and, therefore, could be viewed by anyone, not just followers of the individual Instagram users.
We also understood that there was concern among public bodies in the healthcare field about the potential health risks associated with the prohibited advertising of weight-loss POMs to the public.
We first considered whether the posts were advertising and therefore fell within the scope of the CAP Code.
Paragraph I(h) of the Scope of the Code stated that the Code applied to “advertisements and other marketing communications by or from companies, organisations or sole traders on their own websites, or in other non-paid-for space online under their control, that [were] directly connected with the supply or transfer of goods, services, opportunities and gifts […]”.
We considered that the social media posts, which were promoting a discount code for a pharmacy brand under a referral scheme whereby the poster of the code received payment in kind (a discount off their next order with the brand) when the code was used by a new customer, were directly connected with the supply or transfer of goods or services.
We also considered that the posts, which were in non-paid-for space online, were under Zava’s control. As the operator of the scheme, they could, for example, stipulate how the referral codes were to be shared, impose a cap on the number of referrals that could be made with a code or credits that a member could accrue, and they could decide to revoke existing credits if members did not comply with their terms or guidelines. They therefore had a degree of control over the social media posts of the members of their referral schemes.
For those reasons, we considered the posts were ads under paragraph 1(h) Scope of the Code.
The CAP Code stated that prescription-only medicines (POMs) or prescription-only medical treatments must not be advertised to the public.
The ads all contained references to “mounjaro”. We understood that Mounjaro (tirzepatide) was classed as a POM. We therefore considered the references to “mounjaro” in the ads, whether or not such references were preceded by a hashtag or were part of larger references such as “#mounjaro” in ads (a) and (b), and “#mounjaroweightloss” and “#mounjaroweightlossjourney”” in ad (a) promoted POMs to the public.
Furthermore, we understood that all injectable forms of weight-loss medication were POMs. We therefore considered the references to “injections”, “weightlossjabs” and “weightlosspen” in ad (b), in the context of an ad which included references to Mounjaro, also promoted POMs to the public
For those reasons, we considered that ads (a) – (c) promoted POMs to the public and we 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 Health Bridge Ltd t/a Zava, @mymounjarojourneymrsat, @paigeriley6 and the anonymous Facebook user who posted ad (c) not to promote POMs to the public in future.
