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, 11 February 2026, 18 February 2026 and 8 April 2026.
Summary of Council decision:
Two issues were investigated, both of which were Upheld.
Ad description
Two paid-for Instagram ads for Juniper, an online pharmacy, featured Black Friday promotions, seen in November and December 2025.
a. The first ad, seen on 26 November 2025, featured text stating, “Invest in yourself this Black Friday! Run, don’t walk. Save £179 over 6 months… now that’s a Black Friday sale”. Text in the post’s caption stated, “Medicated weight loss starting from £85, now that’s a Black Friday discount. Forget the flash sales and fast fashion. This Black Friday, choose progress that doesn’t wear off. With Juniper, your best investment is your wellbeing”.
b. The second ad, seen on 2 December 2025, featured a headline that stated, “6 months of weight loss medication, 1 Black Friday discount […] From £85”.
Text in the post’s caption stated, “Medicated weight loss starting from £85, now that’s a Black Friday discount. Forget the flash sales and fast fashion. This Black Friday, choose progress that doesn’t wear off. With Juniper, your best investment is your wellbeing”.
Issue
The ASA challenged whether:
- the ads breached the Code because they advertised a POM to the public; and
- the claims “Run, don’t walk. Save £179 over 6 months… now that’s a Black Friday sale” in ad (a), “6 months of weight loss medication, 1 Black Friday discount” in ad (b) and “Forget the flash sales and fast fashion. This Black Friday, choose progress that doesn’t wear off” in both ads implied a time-limited promotion and therefore irresponsibly pressured consumers into purchasing a medicated weight loss programme.
Response
1. Juniper Technologies UK Ltd t/a Juniper said that when consumers clicked through from the ads, they were taken to an initial webpage with two options: “I’m new to weight loss medication” and “I’m using weight loss medication”. They said they considered that page to operate like a homepage. They understood from the Medicines and Healthcare products Regulatory Agency (MHRA) The Blue Guide that homepages should not expose “casual browsers” to specific POM references. They believed the initial webpages, linked to from the ads, were therefore compliant with the CAP Code, as they did not provide any specific POM information or advertising.
They said they only shared more specific information about their offering once consumers chose to click through from that page. They said consumers who did so were no longer “casual browsers”, but had shown an interest in learning more about weight-loss medication, in the context of their own level of experience (new or existing users).
They said they interpreted the Blue Guide to mean that further webpages about a condition, which consumers chose to access, could provide more specific information in a fair and balanced way.
2. Juniper said they took their responsibility to their consumers seriously. They said they acknowledged the ads implied a time-limited promotion, but did not believe they irresponsibly pressured consumers into purchasing a medicated weight-loss programme.
They believed consumers’ decisions on whether to purchase medicated weight-loss programmes were influenced by multiple factors, beyond price or promotions alone, such as safety, side effects and access to clinical support. They said their market insights showed that promotions were most likely to influence which provider a consumer chose after they had already decided to pursue a medicated weight-loss programme, rather than to pursue one at all.
They also said that the ads did not suggest that consumers could automatically purchase a subscription, but rather, invited consumers to see if they were eligible, or to learn more. They said consumers had to complete an eligibility process, review clinical information and consult with a qualified prescriber before medication was prescribed, which they believed provided ample opportunity for considered decision making, without undue pressure.
Juniper said that the promotion was active from 24 November 2025 through to 5 December 2025, and that both ads (a) and (b) had since been withdrawn from circulation.
Assessment
1. Upheld
The CAP Code stated that POMs or prescription-only medical treatments must not be advertised to the public.
The ASA 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 MHRA’s Blue Guide. We acknowledged that the ads clicked through to an initial webpage with two options: “I’m new to weight loss medication” and “I’m using weight loss medication”.
We considered that a page which simply asked consumers to select whether they were new to weight-loss medication, or already used it, was not a landing page. Instead, we considered it was a filtering page that directed consumers to a landing page akin to a homepage, based on their current usage of weight-loss medication.
After selecting the “new to weight loss” option from the filtering page accessed from ad (a), consumers were taken to a landing page that featured a banner that stated “Limited-Time Offer: Injections From Just £85”. Below that, a headline stated “WEIGHT LOSS Injections UK”. The page also included two product listings, one for Wegovy Injections and another for Mounjaro Injections. The Mounjaro option included a thumbnail image of an injection pen device.
Similarly, the “new to weight loss” option in the filtering page accessed from ad (b) led to a landing page that stated “Limited-Time Offer: Injections From Just £85”. The landing page also featured a large image of a Wegovy branded injection pen device and text that stated, “Weight Loss Injection”. Below was an information box titled “Wegovy [registered trademark symbol] Injections”. A second information box was titled “Mounjaro [registered trademark symbol] Injections”.
We sought advice from the MHRA. They expressed concern that the proactive provision of a direct link to a webpage or landing page that did not require any searching from the consumer to access that information (i.e., Wegovy and Mounjaro) could be analogous to that of a website homepage. MHRA guidance for providers offering medicinal treatment services outlined that homepages should focus on medical conditions and the service provided and should not include any reference to named POMs.
We considered that consumer who had clicked on both ads (a) and (b) and selected that they were “new to weight loss medication” had not sought out further information about a condition, and were actively presented with Wegovy and Mounjaro Injections, both of which were a POM. We therefore considered that the landing page linked to from the ads, via a filtering page, referenced POMs.
For those reasons, we considered the ads promoted POMs to the public and 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).
2. Upheld
The CAP Code required that marketing communications were prepared with a sense of responsibility to consumers and to society. Notwithstanding that the ads breached the Code by promoting POMs, we also considered whether by offering time-limited “Black Friday” discounts, the ads pressured consumers and were socially irresponsible.
We understood that, as well as the POM options referenced in issue one, Juniper also prescribed Alli (60 mg orlistat), an over-the-counter (OTC) medicine used for weight loss. While POMs and POM treatments could not be advertised to the public, we considered that promotions for medicated weight-loss programmes were not necessarily irresponsible where they did not directly promote POMs. However, we considered marketers needed to take particular care when presenting and administering any time-limited offers for medicated weight-loss programmes, whether they involved OTC medication or access to POMs as part of the programme. We considered the decision to sign up to a medicated weight-loss programme should be presented as one that required time and thought from consumers
We also considered guidance issued by the PAGB (Proprietary Association of Great Britain), the trade association representing the manufacturers of branded OTC medicines. Their guidance for Consumer promotions for OTC medicines stated that offers needed to be of reasonable length, as short duration promotions may encourage consumers to make snap decisions that might result in the purchase of medicines that were surplus to their current or foreseeable requirements.
We understood that the promotion started on 24 November and lasted for 11 days. The ads referenced “Black Friday”, which we understood to mean a specific day in the year when retailers offered discounts, which in 2025 was 28 November. While many retailers ran “Black Friday” promotions for several days or weeks around that time, we considered consumers would, in the absence of a stated timeframe in the ads, interpret the references to “Black Friday” to mean there was a strictly time-limited opportunity to take up the offer, that the promotion was going to end soon (on Black Friday or soon afterwards) and that they needed to act quickly to make a purchase at the promotional price.
The ads also included the claims “Run, don’t walk. Save £179 over 6 months… now that’s a Black Friday sale” in ad (a), “6 months of weight loss medication, 1 Black Friday discount” in ad (b) and “Forget the flash sales and fast fashion. This Black Friday, choose progress that doesn’t wear off” in both ads. We considered those claims included urgency messaging and therefore placed pressure on consumers.
By advertising “Black Friday” prices for weight-loss medication which were only available for short periods and with no indication of a specific time frame and by including statements such as “Run, don’t walk”, we considered consumers would be encouraged to make a rushed decision for fear of losing out on the offer. We noted that the offer did not preclude new users of weight-loss medication and therefore those consumers were likely to include new users who were deciding to embark on a medicated weight-loss programme for the first time, as well as existing users of weight-loss medication.
We acknowledged that obtaining weight-loss medication with Juniper involved completing an eligibility process including a consultation with a prescriber. However, we did not consider that was relevant to the presentation of the offer in the ads, because by that point consumers had already made a transactional decision to purchase.
We sought advice from the MHRA, who expressed concern that the ad may not have supported rational use, because it included phrases such as “run, don’t walk”. The MHRA said the appropriate management of a condition should be considered jointly by the prescriber and patient.
Because the ads created a sense of undue urgency to respond quickly, we considered that they had not been prepared in a socially responsible manner and therefore concluded that they breached the Code.
On that point, the ads breached CAP Code (Edition 12) rule 1.3 (Social responsibility).
Action
The ads must not appear again in the form complained of. We told Juniper Technologies UK Ltd t/a Juniper not to promote POMs to the public in future and to ensure their future advertising did not create an undue sense of urgency for consumers considering medicated weight-loss programmes.
