Who this guidance is for

You must follow these rules if you make, advertise, sell or supply products intended for use in, on, or near, animals in the UK.

This includes products such as:

• feeds and supplements
• topical hygiene products
• bedding and housing products
• behavioural products (calmers)

Even if you think your product is not a medicine, you must read and follow this guidance before advertising, selling or supplying it in the UK.

What counts as a veterinary medicine

The Veterinary Medicines Regulations 2013 (as amended) (VMR) define a Veterinary Medicine as:

• any substance or combination of substances presented as having properties for treating or preventing disease in animals; or
• any substance or combination of substances that may be used in, or administered to, animals with a view either to restoring, correcting or modifying physiological functions by exerting a pharmacological, immunological or metabolic action, or to making a medical diagnosis; or
• any substance or combination of substances that may be used for the purpose of euthanising an animal.

Products that need authorisation

Your product needs authorisation as a veterinary medicine before you can sell it if it either:it:

• is ‘medicinal by presentation’presentation’, -this youmeans, presentpresented it as having a medicinal purpose or properties to treat or prevent disease
• is ‘medicinal by function’ - it contains substancesa substance with proven medicinal effects for treating or preventing disease

Understanding ‘medicinal by presentation’

A product ismay be medicinal by presentation if you present it as having a beneficial effect or improvement on an animal’s health problems.

What prevention means

Prevention covers stopping harm to an animal’s health. ThisFor includesexample, a vaccine would be considered a preventative medicine.

Likewise, a product which has the function of destroying parasites that may cause medical conditions.conditions would be considered a preventative medicine.

For example, products that kill fleas on animals are classified as medicines because fleas can cause flea allergic dermatitis.

What disease means

Disease covers a broad range of conditions, including those caused by:

• bacterial, viral or parasitic infections
• systemic dysfunctions
• deficiencies of essential substances

We use the term ‘adverse health condition’ to describe anything wrong with an animal’s health. This includes injuries that pose a significant risk to wellbeing or need more than basic care.

Feed regulations do allow declarations related to nutritional imbalances. Provided these declarations are in line with the appropriate feed legislation, we would not consider them to be medicinal claims relating to disease.

What restore, correct or modify means

Restoring covers bringing back normal function in any body system that is not working properly in an animal.

Example: A product that restores joint function in dogs that can barely walk would be medicinal.

Correcting covers products used to address anyan deficiencyimbalance or dysfunction in an animal,animal’s such as:health.

• nutritional deficiencies
• hormone imbalances
• allergic reactions
• digestive problems

Modifying covers any effect that changes how an animal functions. These are usually enhancement claims suchwhich asgo ‘boosting’,beyond ‘better’,normal ‘promotes’ or ‘stronger’.natural health.

If you claim use of your product will result in the animal’s systems,systems or, anatomy, or health being ‘better‘notably thanimproved’, normal’, your product ismay be considered medicinal. If you claim use of your product will result in the animal being ‘better than an animal with a specific condition’, your product ismay also be considered medicinal.

However, the VMD recognises that this guidance should also be read in conjunction with existing feed regulations. The aim of this guidance is to be used alongside existing feed regulations. We understand that certain feed additives have been authorised to improve an animal’s health and wellbeing and provided these products are being labelled and used in accordance with their authorisation, we would not consider them to be medicinal.

Understanding ‘medicinal by function’

A product is medicinal by function if it contains a substance that the Veterinary Medicines Directorate (VMD) recognises as having a proven medicinal effect.effect for treating or preventing disease.

This includes:

• active substances found in authorised veterinary medicines
• biocidal substances used inside an animal or on open wounds

A published list of substances onthat thewe VMD’sconsidered to be medicinal by function is available to view at MedicinalSubstances recognised as medicinal by Functionfunction Substancein Listveterinary medicines - linkGOV.UK. newYou version should ensure that any ingredient will not make your product medicinal if it does not have a marketing authorisation, as detailed in this guidance. If you have a concern, then you may contact the Enforcement team at enforcement@vmd.gov.uk.

Any product that is medicinal by function must be authorised as a veterinary medicine before you can sell it in the UK.

Substances classified as medicinal by function are not banned. Products containing them must be authorised as veterinary medicines. For example, an authorised CBD-based veterinary medicine would be legal. Any other CBD product for animals would be an illegal veterinary medicine.

Herbal and ‘natural’ products

Herbal products, nutraceuticals and ‘natural’ products follow the same rules as other products. A natural origin provides no exemption.

Traditional medicinal uses

Do not reference the traditional use of a substance for medicinal purposes.

Apurposes substance’sin reputationany formarketing medicinalmaterial propertiesor doeslabelling not exempt you from these rules.

Examples of prohibited claims:

• ‘Everybody knows that…’
• ‘It’s a fact it can…’
• ‘Used for 4000 years to treat…’

You must not reference ‘Traditional Medicine’ as this is explicitly a medicinalnon-medicinal claim.product.

What you can claim for non-medicinal products

Health maintenance

Non-medicinal veterinary products may only be presented for maintaining health in healthy animals.

Health maintenance means providing the materials, hygiene and environment a healthy animal needs to maintain its own health.

Example:health, Afor example a joint supplement providing ‘building blocks’ to support a horse’s joints during competition or intense exercise.

Health maintenance is continuing normal health through non-interventional care.

The word ‘support’ is often used as an alternative to ‘maintain’,‘maintain’ and follows the same rules.

What

Good healthnutritional maintenanceor doeshusbandry notadvice mean

Healthwould maintenance does not includebe claims:

• toconsidered preventmedicinal aunder healththis problemguidance, developing
• ‘against’for anythingexample ora tohorse preventwith harm,low forfibre example,intake ‘maintainsreceiving youra doghigh againstfibre allergydiet/feed. 

  If symptoms’

• thatyour alterproduct’s annutritional animal’sformulation body,supports fornormal example,physiological ‘promotesfunction, amanages healthyrecognised immunenutritional system’
• thatrisk presentfactors yourin producthealthy asanimals aor solutionis toformulated a problem
• using ‘doom’ narratives, for example,the ‘8support out of 10specific horseslife willstages, getbreed thischaracteristics disease’
• toand enhancesupport wellbeing
• toof addressrecognised anythingnutritional wrongsensitivities within anaccordance animal’swith health
• aboutfeed preventinglegislation, deathit or extending life
• using phrases like ‘prevention is betterunlikely thanto cure’,be evenconsidered asto abe company philosophy statement.

medicinal.

What counts as advertising

Advertising includes any activity or content used to communicate information about a product to potential customers.

This includes:

• a company representative at a trade stand talking about the product
• signage on that stand
• the website behind a QR code on the signage
• product pages on websites
• downloadable case studies
• links to scientific journal articles
• social media posts

Use of scientific substantiation to communicate nutritional benefits in a factual and responsible manner is permissible provided this does not imply a medicinal intent.

Types of medicinal claims you must avoid

Direct claims

Do not make specific or implied claims for a purpose or effect that would make the product a medicine.

Examples of prohibited claims:

• ‘Boosts the immune system’
• ‘Balances the digestive system’
• ‘Diarrhoea remedy’
• ‘Promotes‘Prevents jointheart function’disease
• ‘The herbal alternative to Bute’
• ‘Idealphenylbutazone for grumpy tummies’(Bute)’
• ‘Reduces brain aging’pain’

Product names

DoWe would not useexpect to see a product namesname that would imply a specific medicinal purposeeffect orin effect.

Examplesnon-authorised ofproducts, prohibitedsuch names:

• ‘Medisnaxas Dog“Diarrgone Chews’
• ‘Painaid Tincture’
• ‘Diarrgone for Cats’
• ‘FauxBute’

Misspelling,Cats”.  Misspelling, partial spelling or phonetic spelling of a disease in a product name ismay still be considered a medicinal claim if the disease can be easily identified. The same applies to acronyms.

Research and studies

Do not present or reference research data that associates your product with a medicinal purpose or effect.

Example of a prohibited claim:

‘Fortified with Chemical X. Jane Doe et al. The effects of Chemical X on the allergic inflammatory response in midge-sensitive horses. Vet J 1999’

If a product has proven medicinal effects, it must be authorised as a veterinary medicine before you can sell it.

When you present or reference a study, the entire study becomes advertising material. This includes:

• background observations
• how animals were selected
• the author’s speculation on results

You cannot avoid this rule by sending studies privately. For example, saying ‘The VMD told us we can’t publish our study, but leave your email and I’ll send it to you’ still counts as advertising.

Third-party claims

Do not reproduce or reference claims from third parties that present your product as having medicinal properties.

Example of a prohibited claim:

‘Another great review of our product: “Doggy Daycare blue gel worked wonders on my Fido’s atopic dermatitis”’

We would not expect or ask companies to monitor and act against such reviews on third party sites. However, such reviews should not be used by a company to promote a product.

Images

Do not use images that imply a medicinal effect or purpose. This includes before and after images where the animal has a visible health condition or injury that needs veterinary treatment.

Ambiguous claims

Saying a product ‘may help’ does not protect you from making an unauthorised medicinal claim.

Presenting a product that ‘may treattreat’ kennel cough’ is the same as presenting a product that ‘treats kennel cough’. The medicinal purpose is clear.

Disclaimers

Disclaimers do not protect you from presenting a product as having medicinal properties.

Medicinal words and phrases

Many words and phrases have established medicinal meanings when used for veterinary products. The VMD has a list of of medicinal words and phrases you you can refer to.

This list is not exhaustive so should be used as a guide.guide and includes commonly used words and phrases we have seen previously and acted to remove. There may be further words or phrases that would constitute a medicinal meaning, if so then these wouldshould also not be allowedavoided. toThis belist used.is reviewed regularly and amended as necessary.

Rules for testimonials and reviews

Testimonials

If you use testimonials that contain medicinal claims, those claims are treated as your company’s claims.

Third-partyPress content

Claimsreleases, madeadverts byand third parties, such as magazine reviews or articles, are treated as your company’s claims if the third party has a connection to you through:

• solicitation
• endorsement
• sponsorship
• funding
• provision of samples for review

Press releasesadvertorials

If a press release presents a product with medicinal claims, both the company providing it and the party publishing it aremay be responsible for breaching the regulations. However, we would look to take a proportionate approach in line with our published enforcement policy.

Veterinary endorsement

Endorsement by a veterinary professional does not make a product medicinal by presentation. However, it must still follow these rules.

Veterinary professionals and experts are not exempt from making unauthorised medicinal claims.

Customer reviews

If you host and or control your customer review systemsystem, (forfor example, you can remove or prioritise reviews),reviews, the content of those reviews is your company’s responsibility.

AnyIf difficultiesyou inhave monitoringa reviewspublic arereview system on your responsibilitysite, whenwe expect you provideto theensure facilitythat those reviews do not include medicinal claims for customersnon-medicinal products. If they do, then we would expect these to makebe them.removed.

Independent reviews

Reviews are only exempt if they’re entirelypublished underon a third-party control,controlled site, such as some independent review sites.

Yousites, mustlike not:

• haveGoogle the ability to suppress negative reviews
• selectively reproduceor reviews that make medicinal claims

Such actions mean the reviews are considered advertising material and subject to regulation.Trustpilot.

Providing educational materials

You may wish to provide advice on animal care. Any advice given must follow the advertising rules. If this advice relates to health conditions, their causes or effects, it must be completely separate from marketing material for non-medicinal products. Remember, any activity used to encourage the use, sale or supply of a product counts as advertising.

What educational material must not include

Do not:

• referreference to products that are not authorised veterinary medicines for treating that disease or symptom
• include images, links to product pages or directions to your products
• referreference to ingredients in your products that are not authorised veterinary medicines for treating that disease or symptom
• provide links to third-party sources that are prohibited by the above rules
• include data from studies relating to products that are not authorised veterinary medicines for treating that disease or symptom.

Rules for importing products

You are responsible for ensuring imported products comply with these regulations.

If an imported veterinary product has medicinal claims on the label,label it’sor contains a medicinal substance, it may be considered an illegally imported veterinary medicine. YouIt mustis ensurethe importedimporters responsibility to ensure products are legallylegal labelledto import or we may be required to take enforcement action which couldmay include seizing the products.

If you import products for retail, their presentation must comply with this guidance. Other countries may have different approaches to product presentations, so reproducing the manufacturer’s advertising may risk an unauthorised medicinal claim.

Find out more on on Import a medicine for veterinary use into the UK - GOV.UK.

Exception for cascade products

The only exception is for products imported under a VMD certificate by a registered wholesale dealer, pharmacist or vet for use under the prescribing cascade. These products must not be advertised.

Find out more about the cascade: prescribing unauthorised medicines.

Rules for specific product types

Feeds – complementary, compound and supplements

The VMD does not regulate non-medicinal feed products. However, Trading Standards (TS) or the Food Standards Agency (FSA) may regulate them.

What you must not claim

Do not:

• usenot philosophical quotes that imply a medicinal purpose for your feed product. For example, the phrase ‘Let food be thy medicine, and medicine thy food’
• present feed products as having antibiotic, anti-fungal, antiviral, antibacterial or anti-parasitic effects

effects.

Feed ingredients

Having an ingredient on aan officially recognised ingredient list or feed material register doesmay not exempt it from being classed as medicinal by function.

You must ensure that the ingredients are included in line with the requirements of the relevant official ingredient list or feed materials register and that the product is manufactured and labelled in accordance with its feed authorisation.

Substantiating claims

Any evidence you publish to support feed product claims must not present the product as having medicinal properties.

Particular Nutritional Purposes

Some feeds can be used for ‘Particular Nutritional Purposes’ under retainedassimilated Commission Regulation (EU) 2020/354.

You must use the exact wording from the regulation. You must not add extra information about the condition.

Example:For Ifexample, if the approved indication is ‘Support of energy metabolism and of the muscle function in the case of rhabdomyolysis’, you must not add slang terms likesuch as ‘tying up’.

If the VMD has any concern with a product that has been authorised/registered in this way, they will be discussed with the FSA to identify whether the wording breaches any feed regulations in place. In cases where a breach is identified action will be taken by the appropriate agency with responsibility, FSA who would be responsible for enforcing under their regulations, or it may be for the VMD to act under the VMR.

Specific welfare exceptions

The VMD recognises two welfare concerns in UK horses and allows the following product indications and provides the attached guidance:indications:

• Feed products indicated as suitable for horses and ponies prone to laminitis - GOV.UK
• Feed products indicated as suitable for horses and ponies prone to gastric ulcers - GOV.UK

Topical hygiene products, repellents and parasiticides

Biocides are products that control harmful organisms through chemical or biological means. The Chemicals Regulation Directorate regulates these products.

Some biocidal products applied to animals are medicines and must be authorised before being sold.

Products that are medicines

The following products are considered medicines:

• products containing substances that kill insects or external parasites when applied to an animal
• products claiming to affectkill or treat internal parasites; whether chemical or natural
• products claiming to treat or prevent disease caused by viral, bacterial or fungal infection
• products for use inside an animal that have a biocidal effect
• products for use on injuries that need veterinary intervention

Products that are not medicines

A product applied to animals that only contains a repellent is not a medicine, provided it only claims to repel external parasites.

A topical disinfectant applied to intact skin is not a medicine, provided you do not claim it treats or prevents disease.

Hygiene products for minor injuries

A topical hygiene product may be presented for cleaning:

• minor wounds
• minor cuts
• minor abrasions
• superficial tissue damage

You must not claim these products:

• prevent infections
• remove dead, damaged or infected tissue; debriding effects

Bedding and housing products

Products applied to animal bedding and housing must not be presented as having medicinal purposes or effects on animals.

Environmental hygiene products

Products for improving environmental hygiene must not be presented as reducing or preventing disease in animals. This includes references to disease symptoms.

A registered biocide may identify the specific microbes it’s effective against,against but you must not reference the diseases those microbes cause.

Example: You can say ‘effective against canine coronavirus’ but not ‘effective against kennel cough virus’.

Competitive exclusion products

These products use probiotic principles to suppress pathogenic bacteria in the environment. You must not present them as having any medicinal effect on the animal, such as reducing mortality rates or symptoms.animal.

Behavioural products - calmers

These products usually contain either:

• synthetic pheromones that resemble those released by mothers to calm offspring
• herbalfeed productsingredients with calming effects

You must not make medicinal claims for these products.

What you can claim

Restrict claims to maintaining calmness in healthy animals.

What you must not claim

Do not reference:

• pathological behaviour
• psychological conditions such as separation anxiety
• changes to an animal’s brain chemistry
• sedatives or sedative effects; sedatives are medicines

Further help

For guidance on placing a veterinary medicine on the market, see legal requirements for placing a veterinary medicine on the market.

For guidance on advertising authorised veterinary medicines, see advertise veterinary medicines legally.

For guidance on animal feeds and their advertising, contact:

• your local Trading Standards Office
• the Food Standards Agency

For guidance on biocides, contact the Chemicals Regulation Directorate.