CMP-02 · Advertising compliance

Prescription-only medicine promotion checklist

Ten criteria for checking that clinic material does not promote prescription-only medicines to the public, including the workarounds that do not work.

By the Rank My Clinic assessment desk· ·1621 words· 10 criteria

What this instrument establishes

This checklist establishes whether public-facing clinic material promotes a prescription-only medicine. Ten criteria cover direct naming, abbreviations and deliberate misspellings, imagery of packaging, price lists, third-party and influencer content, staff personal accounts, paid advertising, patient-generated content the clinic amplifies, historic material, and the internal rule. The restriction is strict, and the workarounds commonly used in this sector do not change it.

One rule, strictly applied

Of everything in the compliance section of this library, this is the criterion with the clearest rule and the widest gap between rule and practice. Prescription-only medicines may not be advertised to the public in the United Kingdom. The position is set out in medicines regulation and reflected in the advertising codes, and the MHRA Blue Guide explains how it is applied.

The rule does not have a size threshold, a good-faith exception or an educational carve-out that permits promotional naming. It does not distinguish between a paid advertisement and a caption written between patients. It applies to the clinic's own material and to material published on the clinic's behalf.

The workarounds are well known and none of them work. Abbreviating the name, misspelling it deliberately, replacing letters with symbols, using a hashtag rather than body text, showing the packaging without naming it, or letting a patient name it and then resharing the post. The test applied is whether the public would understand what is meant, and in every one of these cases they plainly do.

What a clinic may do is describe the treatment. Explaining what a class of treatment does, who it suits, what it involves and what it costs is not promotion of a specific medicine, and the treatment page quality rubric sets out what such a description should contain. Most clinics find, when they make the change, that product-neutral material is clearer for patients who do not know brand names in the first place.

How to sweep every surface

List the surfaces before searching them: website pages, blog archive, price list, downloadable documents, every social account including ones no longer updated, paid advertising accounts, third-party directory listings you populate, printed material still in circulation, and staff personal accounts used professionally.

Search each for the product names used in your sector, then for each abbreviation, common misspelling and symbol substitution. Search hashtags separately, because they are often excluded from a body-text search.

In paid advertising accounts, check the fields the public does not see: campaign names, asset names, keyword lists and audience names. These are frequently full of product names and are frequently overlooked, and in some platforms they surface publicly in ways the advertiser did not anticipate.

Check images by looking rather than by searching. Packaging, vials and branded promotional materials appear in clinic photography constantly, usually incidentally.

Score each criterion 0 to 3. Where you find a single instance, score that criterion 0 and record where it was. The purpose of the sweep is the list, not the total.

Common scoring errors

Searching only the current website. Archived posts remain published and remain findable.

Treating a hashtag as different from text. It is public-facing material naming the product.

Assuming a patient's own words are exempt when you reshare them. Amplification makes it yours.

Overlooking the price list. Price lists organised by product name are one of the commonest instances and one of the easiest to fix, since the treatment name works better commercially anyway.

Excluding practitioners' personal accounts. Where a practitioner posts about work done at your clinic, the material advertises your clinic.

Rewriting product-led material

The rewrite is usually less painful than clinics fear, because product names carry less meaning to prospective patients than the sector assumes. Replacing a product name with a description of what the treatment does tends to improve the material for readers who are not already familiar with the category.

Describe the treatment by what it addresses, how it works in general terms, how long it takes, what the recovery involves and what it costs. That is what the intent coverage gap analysis asks for anyway, and material written to that specification rarely needs a product name to function.

Where a patient asks about a specific product, answer them in the consultation. A clinical conversation about an individual's own treatment is not advertising, and nothing in this checklist suggests a clinician should be evasive with a patient in front of them.

Write the rule down in one sentence and give it to everybody who publishes anything, including practitioners posting from personal accounts and any third party engaged to produce content. Then check quarterly. This is the one area in the compliance section where the check is worth running more often than the others, because a single post reintroduces the exposure.

CMP-02

Prescription-only medicine promotion checklist

What it measures
Whether any public-facing material promotes a prescription-only medicine, directly, by abbreviation, by implication or through a third party.
What it does not measure
It does not tell you what you may say instead in any specific case, and it is not legal advice.
Scoring method
Criterion referenced. 10 criteria, each scored 0 to 3 against the descriptor given. Maximum 30.
Evidence needed
Every public-facing surface: website, social accounts, paid advertising, printed material, price lists and third-party listings.
Working time
Around an hour.
Who should score it
Whoever approves marketing, having read the relevant guidance first.
Band scale
  • 0 Absent
  • 1 Emerging
  • 2 Established
  • 3 Embedded
  1. 01

    No direct naming in public material

    No prescription-only medicine is named in any public-facing material. Score 0 if any is, 3 if a check has been run across every surface.

  2. 02

    No abbreviations or deliberate misspellings

    Contractions, initials, deliberate misspellings and symbol substitutions that the public would understand are treated as naming. Score 0 if used, 3 if the rule is stated and applied.

  3. 03

    No packaging or product imagery

    Photographs of vials, boxes, syringes bearing product identity or branded materials do not appear. Score 0 if any do, 3 if imagery is checked before publication.

  4. 04

    Price lists describe treatments, not products

    Published pricing refers to the treatment or the area treated rather than a named product. Score 0 if products are priced by name, 3 if the list is product-neutral.

  5. 05

    Third-party content is controlled

    Influencers, partners and suppliers posting about the clinic do not name products. Score 0 if uncontrolled, 3 if the requirement is contractual and monitored.

  6. 06

    Staff personal accounts are covered

    Practitioners posting about their work at the clinic follow the same rule. Score 0 if unaddressed, 3 if the policy covers personal accounts used professionally.

  7. 07

    Paid advertising is checked

    Ad copy, headlines, keywords and asset names contain no product names. Score 0 if unchecked, 3 if checked including the fields not visible to the public.

  8. 08

    Amplified patient content is checked

    Reposting a patient's post naming a product makes it the clinic's material. Score 0 if amplified without check, 3 if screened before sharing.

  9. 09

    Historic material has been swept

    Old posts, pages and PDFs have been reviewed, not only new ones. Score 0 if only recent material was checked, 3 if a full historic sweep was completed and dated.

  10. 10

    A written internal rule exists

    One sentence, known to everybody who publishes anything. Score 0 if it exists only in one person's understanding, 3 if written and circulated.

Total score 0/ 30 Not yet scored

Scoring runs in your browser and nowhere else. Nothing is saved, nothing is sent to us, and closing the page clears it. Print this page to fill the instrument in on paper.

Band interpretations

0 to 10Absent

Public-facing material promotes prescription-only medicines. This is the most frequently enforced issue in aesthetic clinic advertising and the exposure is immediate rather than theoretical.

Next action. Sweep every surface for product names today, including abbreviations. Remove rather than rewrite, and deal with the wording afterwards.

11 to 17Emerging

Recent material has been cleaned and historic material has not, or the website is clean and social accounts are not.

Next action. Complete the historic sweep and extend the rule to staff personal accounts and third-party posts, which are the two remaining sources.

18 to 25Established

Material is substantially clean. Gaps are usually paid advertising fields, amplified patient content or the absence of a written rule.

Next action. Check the non-visible fields in your advertising account, and write the rule down so it survives the person who currently enforces it.

26 to 30Embedded

No public-facing surface promotes a prescription-only medicine, the rule is written, and third parties are bound by it.

Next action. Re-check quarterly and whenever a new channel or partner is added. This is the one compliance area worth checking more often than annually.

Advertising compliance instrument CMP-02. Bands are criterion referenced: they describe your operation against the descriptors above, not against any other clinic. No comparative benchmark for UK aesthetic clinics is published, so this instrument does not pretend to one.

What this instrument does not tell you

  • What you may say instead. The checklist identifies promotion; wording alternatives depend on the treatment and the context.
  • Whether a specific phrase crosses the line. Borderline wording needs advice, not a scorecard.
  • Whether your clinical use of the medicine is appropriate. This concerns advertising only.
  • Whether a patient asking about a product by name may be answered. Clinical conversations are not advertising.
  • How other clinics handle this. Widespread naming of prescription products in this sector is widespread non-compliance.

Every instrument on this site carries this block. An assessment that will not state its own limits is a sales document with a scale printed on it.

Questions about this instrument

Can we name the product in a page aimed at other practitioners?

Material directed at healthcare professionals is treated differently from material directed at the public, but a page on a consumer-facing clinic website is not reliably professional material simply because it says it is. If you publish professional content, it needs a genuine access control rather than a notice.

What about listing products on our price list?

Price lists are public-facing material. Price the treatment or the area rather than the named product. Most clinics find this improves the list, because patients compare treatments and not brands.

A patient tagged us in a post naming the product. Are we exposed?

Their post is theirs. If you reshare, amplify or feature it, it becomes your material. Screen before sharing, which is what criterion eight scores.

Does this apply to devices as well as medicines?

The prescription-only restriction concerns medicines. Devices are governed by different rules, and claims about them are still subject to substantiation and to the advertising codes. Naming a device is not the same issue as naming a prescription medicine.

Our competitors all do this. Why should we not?

Because prevalence is not permission, and enforcement in this area has repeatedly targeted practices that were widespread. The competitive disadvantage is also smaller than it appears, since product-neutral material tends to read better to people who do not know the brands.

Sources

  1. MHRA: the Blue Guide, advertising and promoting medicines
  2. Medicines and Healthcare products Regulatory Agency
  3. Advertising Standards Authority: the non-broadcast advertising code
  4. General Medical Council: guidance for doctors who offer cosmetic interventions

Disclosure. This instrument contains no commercial links of any kind. Rank My Clinic is published by Northbank Media. We do not rank clinics, we do not rank suppliers, and no organisation can pay to influence any criterion, band or interpretation. Nothing here is medical, legal or regulatory advice.

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