Advertising veterinary medicines and price lists

technical advice is our interpretation of how professional standards apply in a particular situation it is designed to help veterinarians deal with common issues in practice, using their professional judgement to apply the advice to their own situation it represents our best efforts at the time of publication but standards and expectations change over time and particular care should be used when reading old advice are restricted veterinary medicine price lists advertising and am i allowed to publish them? a flow chart showing a decision making process for advertising restricted veterinary medicines it captures in visual form the information set out in this article restricted veterinary medicines restricted veterinary medicines (rvms) are agricultural compounds or veterinary medicines (acvm) that have been specially authorised, have an acvm registration number, and require a veterinarian to authorise their administration or sale rvms containing antibiotics cannot be advertised to end users some other rvms also can’t be advertised, such as vaccines against exotic diseases advertising the acvm act (s 2) defines advertisement as, “any publication to the community or to any section of the community of any words (whether written, printed, spoken, or in any electronic form, or of any pictorial representation or design or device) used to promote the sale of any agricultural compound” https //www mpi govt nz/dmsdocument/19445 advertising guidelines for products authorised under the acvm act for products authorised under the acvm act products registered under the https //www legislation govt nz/act/public/1997/0087/latest/dlm414577 html have conditions about advertising attached to their registration the conditions are that advertisements cannot misrepresent, mislead or make false claims about approved product and manufacturing specifications (for example, what the formulation contains, claims on the labels, or storage of the product) make false or misleading claims about the regulatory status of the product pricelists generally, product and price lists for acvm authorised products are not considered advertising any information that may be associated with a product or price list should be limited to either information from the label or the label itself price lists can be paper or digital, including being listed on websites the use of superlatives or comparison claims on either would be considered advertising price transparency veterinarians should make all pricing transparent when providing price lists true transparency consists of more than just product pricing and price lists should also include service fees to enable clients to understand the real costs this is important because a https //hub vetcouncil org nz/glossary#f3bh7 is required to complete the authorisation of an rvm the pricelist document it is important that pricelists can be distinguished from other documents, such as order forms and pre order documents this helps avoid the impression of being buyer driven rather than reflecting a veterinary led problem solving consultation, (including emergency care requirements2 – e g a veterinary authorisation driven approach) advertising rvms the veterinary medicines section of the code of professional conduct sets out https //hub vetcouncil org nz/veterinary medicines#rmkki when advertising rvms, veterinarians must state that the product is only available with veterinary authorisation this could be done with a product availability statement, such as “only available under veterinary authorisation” include the regulatory statement for registered products, you must state that the product is registered under the acvm act in new zealand for example, ‘acvm registration no (a/p/v)xxxx’ this makes it clear when people require a veterinary authorisation requirements of product availability statements for various products can be found https //www mpi govt nz/dmsdocument/19445 advertising guidelines for products authorised under the acvm act only advertise rvms if doing so is unlikely to jeopardise the risk management role of the authorising veterinarian veterinarians should consider the following conflicts of interest a conflict of interest happens when a veterinarian’s duties and responsibilities are affected by another interest, like a personal or commercial interest if you have a conflict of interest do not advertise the rvm inducements/incentives the potential for commercial influence is relevant for decisions involving the authorisation and/or sale of both restricted and unrestricted veterinary medicines while recommending or authorising a particular product that you receive an incentive for (such as a commission or a rebate) may not affect treatment decisions, it could give the appearance that it does, and it could affect veterinary sales decisions the public puts trust in veterinarians and other clinic staff to give them expert, unbiased advice about their animals’ health the perception that some of that advice was influenced by incentives could undermine the veterinarian’s trustworthiness veterinary businesses should also consider the risk of taking incentives, particularly if they become vital to a business model or where their business systems (and ultimately authorising decisions) may be influenced by a need for sales this could undermine the social licence of veterinarians who are relied upon to operate independently do not advertise antibiotics to the public these products have a condition of registration (condition 58) which means advertising for the product must not be targeted at end users such as farmers or pet owners this condition was introduced to help enable prudent use of antibiotics (with a focus on the management of antibiotic resistance) and good product stewardship registrants and veterinarians can provide product label information and safety data sheets to end users, such as farmers and pet owners, if antibiotics are authorised by a veterinarian do not advertise or offer purchase incentives for products with a specific condition of registration that prohibits them being advertised veterinarians may advertise rvms to end users (including offering purchasing incentives) provided there is no specific condition of registration banning this, and the product is not an antibiotic only display a registered veterinary product (and its label) where the public can see it, if doing so does not influence a person’s decision to buy it if displaying a registered veterinary product where the public can see it, the advertising veterinarian must tell the potential buyers that they need to discuss treatment options with their veterinarian information transfer advertising does not include general information transfer or disease state awareness it is important that the industry provides good advice on using agricultural compounds and veterinary medicines, and also understands when information transfer crosses into advertising advertising versus information transfer in publications two of the key factors to consider are vested interest (e g direct financial gain from the sale of the product); and specifying a trade name if these factors go together, it is often considered advertising to learn more about information transfer, refer to the https //www mpi govt nz/dmsdocument/19445 advertising guidelines for products authorised under the acvm act for products authorised under the acvm act condition 66 many rvms are subject to condition 66 which places limitations on acceptable content and states that no advertisement for the product may include content, or be presented in a manner, that does not conform to the approved product and manufacturing specifications (this includes approved uses) contain false or misleading claims, statements or information in relation to the product, or make false or misleading claims or statements about the regulatory status of the product, either directly or indirectly, under the acvm act information transfer on restricted veterinary medicines containing antibiotics there will be situations (that are not considered to be part of a veterinary consultation) where the end users, such as farmers, need information about treatment options that specifically relate to using antibiotics this means information should reference the appropriate use of antibiotics and not specific trade names this could be communicated through veterinary newsletters; social media; at farmer field days; on the registrant’s website; or specific forums what is considered acceptable information transfer can depend on the forum examples include information on how an active ingredient works and when it would be appropriate to use it general information on how antibiotics are classified for educational purposes surveillance data on antibiotic sensitivity in nz dairy herds any materials intended for end users, or to which end users might be exposed, should not include website links (new zealand or overseas) to trade name products containing antibiotics websites advertising rvms containing antibiotics (including products for purchase) in accordance with condition 58 should be managed so that access is restricted to veterinarians and/or people with appropriate acvm approvals risks with off label use any off label use of a product has the potential to cause residues, animal welfare/plant safety concerns, or efficacy issues that were not assessed during its registration process therefore, off label uses must not be advertised products that must not be advertised advertisements cannot be created to sell a product that is not authorised by acvm but should be for example, products undergoing the acvm class determination and approvals process if you are unsure if a product has acvm authorisation, you can check the acvm website for information keep in mind the section in this technical guidance about listings and price lists that has a provisional registration, research approval or any other approval under special circumstances (the condition of approval in these situations does not permit advertising in any way) that is a compounded veterinary preparation or prescription human medicine authorised by a veterinarian for patients under their care that has special approvals/conditions, such as biosecurity requirements