Who: The Advertising Standards Authority (ASA); UK Meds Direct Ltd t/a UK Meds Direct; MedExpress Enterprises Ltd t/a MedExpress; Health Bridge Ltd t/a Zava
Where: United Kingdom
When: 11 February 2026
Law stated as at: 5 March 2026
What happened
The ASA has published several rulings against online pharmacies, all arising from customers and influencers sharing referral codes for the weight-loss injection Mounjaro on public social media accounts.
Mounjaro is a prescription-only medicine (POM), and the rulings form part of a wider piece of work by the ASA on POMs used for weight loss. (See also this MarketingLaw article.) The UK Code of Non-broadcast Advertising and Direct and Promotional Marketing (CAP Code) states that POMs or prescription-only medical treatments must not be advertised to the public.
The schemes
All three companies ran incentive schemes rewarding existing customers for bringing in new ones. UK Meds Direct operated an affiliate scheme offering commission once 100 new customers used a referral code. MedExpress and Zava each operated refer-a-friend schemes offering credits or discounts when new customers used a shared code.
The posts
Influencer posts promoting a referral code from UK Meds Direct included a video of a woman discussing what she ate in a day on Mounjaro, promoting a code for money off a “pen”, and a video of a woman claiming to have lost “66 pounds on Mounjaro” and holding a Mounjaro KwikPen medication, promoting £10 off with a referral code. Both posts included hashtags such as #mounjaro.
MedExpress customers’ posts included a £40-off MedExpress referral code with hashtags including #mounjaro, #mounjarojourney and #glp1weightloss. One of the posts featured an image of three Mounjaro injection pens of different dosages with associated equipment, and another post included a video of a woman holding a box of Mounjaro pens.
One Zava customer’s post included a 15%-off code and hashtags such as #mounjaro. Another post promoted a 25%-off code and stated “ZAVA promo code for MJ”, including the hashtag #mounjaro. An anonymous post in a public online group included a 25%-off code with the caption “just started my mounjaro journey”.
The pharmacies’ arguments
UK Meds Direct acknowledged that the influencers were engaged in its now-discontinued affiliate programme, and to ensure compliance, it had also permanently discontinued influencer marketing and disabled its “refer a friend” feature for all POM products.
MedExpress said that it had not created or commissioned the posts in question and did not have any contracts or specific relationships with the users beyond the referral code programme. It also said that it informed customers that they should not be promoting or “calling out” POMs, and that its terms and conditions stated that POMs are prohibited from being advertised to the public and included consequences for customers who shared referral codes in violation of those terms. MedExpress had cancelled the reward credits of the individuals who posted the ads.
Zava stated that it had no commercial relationships with the posts’ authors and did not run an affiliate scheme. When contacted by social media users seeking commercial sponsorship, its policy was not to engage. Zava said that its discounts and referral codes applied to all its services and not just POMs, but it had since reviewed its materials to ensure that no discounts or referral codes were directed at POMs.
The ASA’s ruling
The ASA highlighted that the posts were made from public accounts and therefore could be accessed by anyone. The ASA considered that the references to “Mounjaro”, images of Mounjaro packaging, and references to “pen” in the context of ads that included references to Mounjaro, all constituted promotion of a POM to the public, in breach of the CAP Code.
In relation to Zava’s ads, the ASA also determined that the posts were under the company’s control. It stated that, as an operator of a referral scheme, Zava could, for example, dictate how the codes were shared, cap the number of referrals, and revoke credits for non-compliance, giving it a sufficient degree of control over the posts.
As a result, the ASA upheld all complaints, and the pharmacies, along with the individual account holders, were told not to promote POMs to the public in future.
Why this matters
The ruling against Zava highlights that a business operating a referral or affiliate scheme remains responsible for the advertising generated through that programme, even where customers are the ones posting. Having terms and conditions that prohibit POM promotion is insufficient if the business retains meaningful control over how the scheme operates. Any business running such a scheme in relation to a product that is wholly or partly a POM should review its approach to avoid falling foul of the CAP Code.
