Background
This ruling forms part of a wider piece of work on prescription-only medicines (POMs) used for weight loss. See also related rulings published between 9 July 2025 and 29 July 2026.
Ad description
A paid-for Reddit ad for SheMed UK, female-focused medical weight-loss service, seen on 30 March 2026, included a headline that stated “I think ‘skinny fat’ explained why I felt stuck”.
Text underneath stated “I wasn’t obese on paper, but I felt soft, tired, and constantly thinking about food. Dieting made me smaller, not healthier. Exercise helped… until it didn’t. Turns out ‘skinny fat’ often comes down to body composition, hormones, and how your appetite is regulated - not just calories. That’s what pushed me to look into medical weight loss, not to lose more weight, but to fix what felt off. SheMed’s doctor-led medical weight loss programme focuses on appetite biology, with proper clinical support throughout. Not saying it’s for everyone. But it reframed weight loss for me completely. Curious if anyone else relates to the ‘skinny fat’ thing”.
The ad included links labelled “SheMed’s doctor-led medical weight loss programme” and “SheMed’s ‘low and slow’ programme”.
Issue
The complainant challenged whether the ad:
- breached the Code because it promoted prescription-only medicines (POMs) to the public; and
- was socially irresponsible because it exploited consumers’ insecurities relating to body image and weight, particularly those who did not need to lose weight, in order to promote a medical weight-loss service and whether it implied that the medicines were suitable for consumers outside their licensed indications.
Response
1. SheMed Ltd t/a SheMed said that the landing page from the ‘low and slow’ programme link in the ad included images of GLP-1 pens and brand names but pointed out that this page was not the home page of its website. The said they had since removed the ad, and they would not run it again in the future.
2. SheMed said GLP-1 medicines were licensed for adults with a BMI of 30 or above, or for those with a BMI between 27 and 30 who also had at least one weight-related comorbidity. They said the post stated that the individual was not obese, but did not state that they were not overweight. They also said the post made clear that the individual felt “tired” and “off”, and referred to hormones, which they believed could indicate a relevant comorbidity, including conditions such as polycystic ovary syndrome. They accepted that the link between being overweight and having a comorbidity could have been made clearer in the post. They said they did not, and would not, prescribe weight-loss treatments to adults who were not overweight and did not meet the prescribing criteria.
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 the Medicines and Healthcare products Regulator Agency’s (MHRA) The 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 ‘low and slow’ link in the ad took consumers to a landing page which featured images of branded Wegovy (semaglutide) and Mounjaro (tirzepatide) weight-loss injection pens. We understood that Wegovy and Mounjaro were both POMs.
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 home pages should focus on medical conditions and the service provided and should not include any reference to named POMs.
Because the landing page linked to from the ad referenced POMs, we considered the ad promoted POMs to the public and concluded that it breached the Code. We welcomed SheMed’s assurance that they had removed the ad.
On that point, the ad breached CAP Code (Edition 12) rule 12.12 (Medicines, medical devices, health-related products and beauty products).
2. Upheld
The CAP Code requires marketing communications to be prepared with a sense of responsibility to consumers and to society. We considered that particular care should be taken when preparing advertising for medicated weight-loss services, given that some consumers, particularly young women, may already feel body conscious due to wider societal pressures, regardless of their actual weight or size, including those who are of a healthy weight. The Code also required that marketing communications for medicines must conform with the licence and the product’s Summary of Product Characteristics.
We understood that the Summary of Product Characteristics for Wegovy and Mounjaro that the medicines were indicated for adults with obesity (BMI ≥30 kg/m²), or adults who are overweight (BMI ≥27 kg/m²) who had at least one weight-related comorbidity.
We considered the references in the ad to “I wasn’t obese on paper”, “I think ‘skinny fat’ explained why I felt stuck” and “Curious if anyone else relates to the ‘skinny fat’ thing” were likely to be interpreted to mean the person referenced in the ad who had accessed SheMed’s weight-loss service was of a normal weight or was underweight but were nevertheless unhappy with their body shape or composition. The ad did not refer to the person being overweight and having a medical condition which would constitute a weight-related comorbidity. We considered that references to feeling “tired” and “off”, as well as “hormones”, were not sufficient to convey that the person in the ad had a weight-related comorbidity.
In that context, we considered the ad positioned a medical weight-loss programme as being suitable for consumers who did not meet the licensed criteria for the medicines featured on the linked page (Wegovy and Mounjaro).
We sought advice from the MHRA. They expressed concern that the ad did not meet Quality Standards required for an advertisement for a medicinal product (which included, to be consistent with the Summary of Product Characteristics).
For those reasons, we considered the ad did not conform with Wegovy and Mounjaro’s licence and the products’ Summary of Product Characteristics, it was likely to exploit consumers’ insecurities relating to body image and weight, and was irresponsible.
On that point, the ad breached CAP Code (Edition 12) rules 1.3 (Social Responsibility) and 12.11 (Medicines, medical devices, health-related products and beauty products).
Action
The ad must not appear again in the form complained of. We told SheMed Ltd t/a SheMed not to promote POMs to the public in future and to ensure any ads for non-POMs conformed with the Summary of Product Characteristics in the relevant marketing authorisation. We also told them to ensure their future advertising was prepared with a sense of responsibility to consumers and society.
