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AuthorsRichard HoughThorrun Govind
5 min read

When it comes to supplying weight loss medications, there are a number of critical factors that prescribers must take into consideration.
In January 2024, the BBC conducted an investigation into prescription drugs that were being sold online without robust checks. This poses a huge risk for pharmacy owners from both a compliance and reputational point of view. Additionally, in June, it was reported that women were attending A&E after abusing weight loss medications purchased online.
Here, Richard Hough, Partner and Head of Healthcare and Thorrun Govind, Solicitor in our regulatory and professional conduct team share practical guidance for pharmacists on remaining compliant and ethically promoting a weight loss service.
This article was originally published in the Independent Community Pharmacist on 9 August 2024.
A good starting point in remaining compliant is consulting the latest information published by the General Pharmaceutical Council (GPhC). This forms part of the standards that patients and the public will expect when accessing pharmacy services.
Earlier this year, the GPhC advised that while face to face care isn’t mandatory, the mode of consultation should be “appropriate to meet the needs of the patient” and should ensure that the prescriber has enough information to make an appropriate prescribing decision.
For the prescription of weight loss treatments to be deemed safe, the pharmacy has a responsibility to conduct ongoing monitoring of the patient, ensure weight and height information is accurate and verified, and talk to the patient about their needs. Prescribers must remain vigilant that eating disorders, body dysmorphia and mental health issues could be the reason behind patients requesting these medicines.
Shortages of licensed weight loss medication such as glucagon-like peptide-1 receptor agonists (GLP-1 RAs) also resulted in the GPhC taking action against pharmacies for inappropriately supplying medicines that are licensed for treating diabetes for weight loss. Therefore, this needs to be considered in the context of the January 2024 National Patient Safety Alert which requires pharmacies to prescribe medicines for licensed uses only and not off-label to manage obesity.
Further to this, the Royal Pharmaceutical Society’s prescribing competency framework outlines what responsible prescribing looks like and presents useful considerations for those supplying medications.
The Medicines and Healthcare products Regulatory Agency (MHRA) controls medicines and medical devices in the UK and is responsible for ensuring that medicines and medical devices work and are acceptably safe.
The MHRA’s Blue Guide provides guidance and legislative requirements on advertising and promoting medicines, including weight loss treatments. It also provides additional clarification on the interpretation of the law and its application to commonly encountered situations and queries from patients.
Importantly, rule 12.12 in the Advertising Standards Authority (ASA) Code of Conduct states that prescription-only medicines (POMs) mustn’t be advertised directly to the public. It’s also an offence under the Human Medicines Regulations 2012 to publish an advertisement that is likely to lead to the use of a POM.
To ensure your website and marketing collateral remain compliant, the Blue Guide outlines how the home page of websites should be configured – including guidance against “buy now” or ‘’add to basket’’ icons. The ASA has also confirmed that marketing should not influence that a medical consultation is unnecessary, for example by offering a diagnosis or suggesting treatment by post, electronic communication or telephone.
However, these advertising rules do not mean it’s not possible to talk about the services you offer. The focus should be on promoting a consultation for a particular condition, such as weight management, (i.e. the service) rather than promoting a named POM that could be used to treat the condition.
The GPhC further confirms that it expects pharmacy owners to ensure that their websites do not allow a person to choose a POM before there has been a consultation with a prescriber.
Digital Clinical Excellence (DiCE) UK Forum Best Practice Guidance also includes recommendations about how to offer an asynchronous weight management service, i.e. where a health assessment is undertaken remotely, gathering pertinent medical information using an online assessment form, which is then reviewed by a clinician before a prescription is issued.
However, the PDA has recently reported that a number of pharmacists who use the questionnaire mode of consultation are being investigated by the GPhC, as there is a risk that it is inappropriate to provide weight loss treatments solely based on a questionnaire without verifying the accuracy of the information provided by the patient.
The GPhC has shared examples of good practice when it comes to weight management. This includes comprehensive prescribing notes — which can be accessed by other prescribers — as well as consultation and counselling methods like bespoke information leaflets, administration videos and follow-up by video or telephone.
With the increasing demand for weight loss POMs, it’s crucial that pharmacists review their existing practices for supplying these medicines and can be comfortable that — if scrutinised by the GPhC — they can evidence that their processes support the safe and effective provision of weight loss medication.
Our experienced and specialist multidisciplinary pharmacy law team includes practising and former pharmacists with a unique understanding of the challenges that our clients face.
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Richard Hough
Richard is a Partner. He leads our commercial and IP team as well as our healthcare sector team.
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