Promotion of unlicensed botulinum toxin medicines at a UK conference: March 2025
Published 11 April 2025
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Merz Pharma UK Ltd complained about promotional activity by several international aesthetic companies at a CCR conference, described as “the UK’s flagship event”, held in London on 10–11 October 2024.
The complainant alleged that botulinum toxin medicines that did not have a UK Marketing Authorisation or equivalent were being promoted at company stands through display materials and/or vials of the product and dissemination of information about the product. MHRA upheld the complaint.
The following companies have therefore agreed to review their procedures to ensure in future that no promotional materials referring to medicinal products that do not have a UK Marketing Authorisation are displayed, and attention is not proactively drawn to such products during discussions/interactions, at conferences focussed on UK attendees:
- Dermax
- JDBio Co Ltd
- Visionmed Ltd
Regulation 279 of the Human Medicines Regulation 2012 prohibits the advertisement of medicinal products that do not hold a valid Marketing Authorisation. While the prohibition does not prevent factual answers to unsolicited questions about an unlicensed medicine, any activity that appears to be designed to solicit such questions would be considered promotional and in breach of the prohibition (for further information, see chapter 4 of the MHRA Blue Guide).