Promotion of OTC medications

In addition to the Consumer Rights Act  a pharmacy must consider in particular any promotions relating to over the counter medicines as many permitted promotional techniques for general consumer goods are also lawful for these products. However, promotions of these items may be neither ethical nor in the best interests of consumers. Guidance from the RPS states that any promotions must not promote inappropriate or excessive use of medicines or encourage customers to buy medicines not needed. The PAGB (Proprietary Association of Great Britain) is a national trade association representing manufacturers of branded OTC medicines and food supplements and provide the following advice to consider:

Discounts - any money off promotion for an OTC medicine should not be excessive, to avoid customers purchasing supplies surplus to their requirements and as a general rule no more than a 50% reduction. Volume sales promotions such as 'buy one get one free' are seen as undesirable, especially in products which have potential for misuse or accidental poisoning, e.g. paracetamol. It may only be suitable if the product is intended for long term use such as a nicotine replacement therapy or some weight loss treatments and other retail items within the pharmacy such as cosmetics.

Gifts with purchase - if offering a gift with purchase this should ideally be relevant to the product purchased and of a lower value, to avoid people purchasing any medicines they do not need simply because they want the free product. An example of an acceptable promotion would be offering a free carry case with the purchase of a blood pressure monitor.

Free samples and loyalty points - it is not acceptable for free samples of medicines to be provided to customers. It is acceptable for a pharmacy to offer loyalty points on medicines if not excessive, but never prescription medicines or charges and the use of the loyalty points should not result in the customer being able to purchase a medicine free of charge. The Numark loyalty card scheme allows customers to earn stamps when they spend within the pharmacy which they can then exchange for vouchers, which can be redeemed by customers in line with this guidance.

To ensure best practice on the above, further guidance on promotions for OTC medicines is available at this link taken from the PAGB website. PAGB Advertising