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AgVetLink August 2004: Page 4

Advertising PARs

The ACVM Standard for Prescription Animal Remedy Veterinary Medicines states that:

A trader may advertise as an approved trader in PAR products and may indicate the types of PAR products stocked.

A trader must not display PAR products in public view.

As a basic principle, a trader should focus any advertising or promotion of PAR products to registered veterinarians who can legitimately prescribe the products. They should provide accurate and technically supportable information about their products that allows prescribing veterinarians to make informed judgements in regard to their use.

It is quite appropriate for traders to provide technical information on products and to foster awareness and understanding of disease conditions or health and production management options.

In doing this it is reasonable for them to identify themselves or their company with the information and mention that they market a product or products that could be used to treat a particular disease condition or contribute to the management of health or production.

However, they must not promote the products as the preferred choice and must emphasise that end users should discuss treatment options with their veterinarian. They must not offer any purchasing incentives to end users or carry out any advertising campaigns targeting end users or face-to-face contacts with end users to promote particular PAR products.

These requirements relate only to advertising or promoting PAR products directly to the end user.

Conflicting opinions

Some members of the veterinary profession and other animal health care specialists have argued that the advertising practices of some parties have resulted in serious conflicts between them and their clients who, as a result of the advertising or promotion, demand products that the veterinarians do not consider appropriate under the particular circumstances. This same concern (and for the same reason) has been raised in regard to direct to consumer advertising of human medicines.

On the other hand, some veterinarians, end users, registrants of products, wholesalers and retailers have argued that the ACVM Group’s requirements are unnecessarily restrictive. They consider that the prohibition on advertising may deny end users access to products because their veterinarians may be unaware of the products or, for some non-technical reason, would not prescribe some acceptable alternative.

The ACVM Group accepts that both arguments are reasonable and likely to be correct at times.

Standards

If all parties acted in a responsible manner there would be little need for the ACVM Group to set requirements in regard to advertising. However, experience has shown that such reasonable behaviour does not always prevail.

The ACVM Group’s preference is that all parties set standards for responsible behaviour when it comes to advertising PAR products. Some industry associations and the New Zealand Veterinary Association have attempted to establish such a standard, but self regulation has not always been effective across the wider industry.

The ACVM Group’s Standard for Prescription Animal Remedy Veterinary Medicines states the expectation that persons authorised to sell PAR products will exercise care not to jeopardise the ability of a veterinarian to prescribe the product considered most appropriate under the circumstances.

However, it recognises that there is often important information that the end user should have access to that could be supplied at the point of sale.

The ACVM Group does not consider such information to be advertising.

The ACVM Group reserves the term ‘advertising’ for promoting a particular product in preference to other comparable products in order to increase the sales of that product. The Group recognises that traders are in business to sell the products they stock. Its restrictions on advertising focus on practices that encourage the end user to demand particular PAR products when the prescribing veterinarian may consider the use of some other PAR product (or not treating an animal at all) is the more appropriate course of action.

The ACVM Group intends to maintain the expectations as stated in the standard. The Group will actively participate in discussions with interested and affected parties to develop any refinements that make information on products readily available to all parties while protecting veterinary prescription as a mechanism to ensure the most appropriate products are used effectively and safely. However, the Group considers these expectations as guidance only.

Compliance will not be mandatory unless there is a specific product condition prohibiting advertising to end users.