Background
This ruling forms part of a wider piece of work on POMs used for weight loss, identified for investigation following complaints received. See also related rulings published on 9 July 2025.
Summary of Council decision:
Two issues were investigated, both of which were Upheld.
Ad description
A comment and posts in weight-loss support groups on Facebook, seen in September 2025:
a. A reply to a post in a group titled “Mounjaro weightloss [sic] supportUK” from Aqsa Bilal stated, “Juniper’s lower wegovy price is a solid deal tbh 25% cheaper than mounjaro. weight loss results like mounjaro, worth checking while it lasts.”
b. A post in a group called “mounjaro ozempic wegovy weight loss support” from Mae-Neillen Mapenhag stated, “First-time Juniper customer here – ordered Saturday, delivery came today! I can share my code for £85 off if anyone’s interested. I’ll also get £85 off my next order, so it’s a nice bonus for both of us!” In a reply to a comment on the post, the author then stated, “Juniper is taking new Mounjaro – discount code is REF-JENU-NBL8”.
Issue
CheqUp Health Ltd, who believed the posts and the comment had been paid for by Juniper, challenged whether they:
- were obviously identifiable as marketing communications; and
- breached the Code because they promoted prescription-only medicines (POMs) to the public.
Response
Juniper Technologies UK Ltd t/a Juniper said that they had stopped the communications, as part of improving compliance, before receiving contact from CheqUp Health Ltd and the ASA.
Juniper said they engaged the individuals, for a brief period of time, to post authentic comments about Juniper. Juniper said the individuals retained editorial control and were paid on an hourly basis; they were not incentivised on a per-click or per-post basis.
Juniper said that they had reviewed the content posted and had decided that the approach was not appropriate. They said they had ended the engagement of the individuals promptly and independently.
Assessment
1. Upheld
The ASA first assessed whether the posts (a) and (b) were marketing communications that fell within the remit 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 understood that Aqsa Bilal and Mae-Neillen Mapenhag were marketing professionals who were not based in the UK and were not users of Juniper’s services. We understood they had been contracted by Juniper to post content on Facebook about Juniper and that both posters had been paid on an hourly basis. We therefore considered that the posts made by Aqsa Bilal and Mae-Neillen Mapenhag in their capacity as representatives of the brand constituted marketing communications in non-paid-for space under the control of Juniper. Post (a) named Juniper and featured references to the price of services that they provided. Post (b) featured a discount for services offered by Juniper. Because the content of both posts promoted services that could be obtained from Juniper, each post was directly connected to the supply of goods. We therefore considered that the posts, that were under Juniper’s control and directly connected to the supply of goods, were marketing communications that fell within the remit of the CAP Code.
We next considered whether the posts were obviously identifiable as marketing communications and whether they made their commercial intent clear.
The posts appeared in public Facebook groups for discussion of weight-loss support and were posted from Facebook accounts which did not appear to be affiliated with Juniper. We considered that the posts gave the appearance of being from users of Juniper's services, for example ad (b) contained the text “First-time Juniper customer here”. Furthermore, the posts did not contain any ad labels, or any other indication that the posts were marketing communications. For those reasons, we considered the ads were not obviously identifiable as marketing communications, did not make clear their commercial intent and therefore breached the Code.
On that point, ads (a) and (b) breached CAP Code (Edition 12) rules 2.1 and 2.3 (Recognition of marketing communications).
2. Upheld
The CAP Code stated that POMs or prescription-only medical treatments must not be advertised to the public.
Ad (a) referred to “Wegovy” and “Mounjaro” and ad (b) to “Mounjaro”. We understood Wegovy (semegultide) and Mounjaro (tirzepatide) were classed as POMs. We therefore considered those references in the ads promoted POMs to the public.
Because the ads promoted POMs to the public, we concluded that they breached the Code.
On that point, ads (a) and (b) 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 Juniper Technologies UK Ltd t/a Juniper to ensure that their future posts were obviously identifiable as marketing communications and made clear their commercial intent, for example by including clear and prominent identifiers, such as “#ad”. We also told them not to promote POMs to the public in future.
