UK law permits the remote supply of all categories of veterinary medicines, provided the general legal requirements regarding the prescription and supply are met.

Such supply is commonly associated with internet sites. Although these are often informally described as ‘pharmacies’, the majority are currently hosted by veterinary practices under the professional control of veterinary surgeons, and thus are not legally pharmacies at all. Some internet sites are true pharmacies controlled by pharmacists, and a number of sites are under the professional control of suitably qualified persons (SQPs).

As well as online ordering, some businesses promote mail order supply of veterinary medicines through more traditional printed price lists and advertisements, and others may supply medicines by post/courier on an ad hoc basis as an occasional customer service.

Legislative requirements
There are no legislative requirements specific to the supply of veterinary medicines ordered online or through direct mail. The general requirements of UK legislation apply to the prescription and supply of medicines, irrespective of whether a client physically visits the premises and meets the veterinary surgeon (or pharmacist/SQP) face-to-face. A veterinary surgeon supplying drugs online or through direct mail ordering must be able to demonstrate that they operate in accordance with the Veterinary Medicines Regulations (VMR), including the registration and inspection requirements with respect to the premises.

As a result, although the supply of medicines ordered online or via direct mail can be carried out legally, veterinary medicines (other than AVM-GSL and Small Animal Exemption Scheme (SAES) medicines) should not be offered or supplied via auctions, since legal and professional obligations cannot be met satisfactorily.

Premises that supply medicines ordered online or via direct mail under the professional control of a veterinary surgeon must be registered as a veterinary practice.

Prescription
The requirements for the prescription and supply of veterinary medicines are the same for remote supply as for face-to-face interactions. However, key points to bear in mind include:

• Veterinary surgeons must ensure that they have sufficient information to make a clinical judgement about the animal and the correct medicine to prescribe
• POM-V medicines may only be prescribed for animals under the veterinary surgeon’s care
• POM-VPS medicines may be prescribed for animals not under the veterinary surgeon’s care, but the other professional and legal obligations must be met.

Prescriptions may be faxed or emailed to an internet or mail order supplier. Electronic transmission of prescriptions for Controlled Drugs is not allowed.

Suppliers should seek to ensure that a prescription is only filled once. It is good practice if the supplier does not recognize the prescriber’s signature to take steps to ensure that the prescription is genuine.

Veterinary surgeons providing a written prescription should seek to ensure that it will be legally filled.

Supply by post
Veterinary surgeons may legally supply medicines by post/courier, whether operating from a traditional veterinary practice, an internet site or a mail order service.

Veterinary surgeons should take account of whether the medicines are potentially harmful to the general public. Medicines not in the manufacturer’s packaging should be supplied in child-proof containers. Appropriate safeguards should be taken to protect the medicine in transit; for example, medicines that are in liquid form will require different safeguards from those that must be kept refrigerated. In general, Controlled Drugs should not be sent via the post, but if this is essential then they should be sent at least by recorded delivery to ensure an audit trail, and preferably via a service which ensures that the Controlled Drugs are only handed over to a competent adult.

The standard legal obligations on suppliers apply, including:

• Being satisfied that the person who will use the medicine is competent to do so safely, and intends to use it for a purpose for which it is authorized
• Advising on safe administration and on any necessary warnings or contraindications on the label or package leaflet
• Supplying only the medicine named on the prescription; unlike in human pharmacy, generic substitution is not permitted.

Examples
The following examples demonstrate some of the ways in which the requirements of duties at the time of supply can be met, including methods for use by internet and mail order retailers. This is not an exhaustive list and it is up to the retailer to choose their own method.

• It is considered good practice for all businesses supplying veterinary medicines to display clearly the appropriate authorization details (e.g. the name and registered number) of the veterinary surgeon, pharmacist or SQP who is responsible for prescription and/or supply, and this person should be available to advise clients directly.
• It must be possible for a client to be given direct advice so that the most appropriate medicine is prescribed and/or supplied to them, regardless of the medicines that the supplier currently holds in stock, those that are reduced in price, or those which are being promoted through the business by the manufacturer.
• Even if a client asks for a specific POM-VPS or NFA-VPS medicine, there must be an interaction between the client and the supplier to ensure that the medicine selected is appropriate for the animal to be treated and its circumstances (including husbandry and condition).
• For clients who wish to order specific POM-VPS or NFA-VPS medicines over the internet, an online registration system should be set up so that details of the client and of the type, number, size, age, weight, etc., of their animals are recorded, kept up-to-date, and can be used to enable a supplier to make the necessary checks on the suitability of the medicine ordered before any medicines are prescribed and/or supplied. This would also enable returning customers to log-in without having to provide the information again, unless it has changed, and there should be a confirmatory declaration with each order to this effect.
• Internet suppliers may also set up an online questionnaire for completion by clients to confirm whether they have administered the medicine previously, if they are aware of the relevant safety precautions relating to the medicine, and to confirm that they will read the packaging and product literature before using the medicine.
• An email or telephone call may be made to the client following placement of their order to enable the supplier to discuss any problems before filling the prescription and or/supply. This approach would be considered good practice and must happen if there is any missing or conflicting information.
• All information provided must be carefully checked by the authorized supplier before any supply is made.
• Records of such interchanges with clients (via the internet, emails, phone calls) should be made and retained.

Price lists
Advertising of prescription-only medicines (POM-V and POM-VPS) is only permitted to defined groups, which does not include pet owners, clients or the general public. However, price lists (whether printed or online) may be supplied to the general public, provided certain conditions are met:

• The text and images displayed must all be of the same size and type; it is unacceptable for a single medicine on a price list to feature more prominently than the rest
• The name of each medicine, its image and a description may be shown within a price list, providing that the wording is in accordance with the medicine’s published summary of product characteristics (SPC). The name of the medicine should be exactly as per its full authorized name. This is important, as different medicines within the same brand should be clearly distinguished
• A description may be given, for example ‘dog flea treatment’, as long as this is in accordance with the SPC
• Any image of packaging used must show the UK authorized packaging.

Non-UK websites
UK law requires that (save for the exemptions provided to veterinary surgeons under the cascade) only authorized veterinary medicines should be used.

It is an offence for an animal owner:

• To be in possession of a veterinary medicine not lawfully supplied in the UK (including, where appropriate, lawfully prescribed)
• To administer a veterinary medicine unless it has a marketing authorization valid in the UK
• To import a veterinary medicine into the UK, even if authorized for use in the UK (except for AVM-GSL medicines)
• To supply a veterinary medicine to another person, other than as legally required.

It may be helpful for veterinary surgeons to ensure that animal owners requesting a written prescription, or otherwise contemplating sourcing medicines via the internet, are aware of the importance of using a UK-based and legal site. Only by doing so can owners be sure that their animals will receive safe and effective medicines – and avoid breaking the law themselves. Illegally sourced medicines may be counterfeit, ineffective, or unsafe for the client’s animals.

Useful websites
Royal Pharmaceutical Society of Great Britain
RPSGB Guidance on Internet Pharmacy Services
 

Veterinary Medicines Directorate (VMD) 
Veterinary Medicines Guidance Note 3 –
Veterinary Medicinal Products: prescription, distribution categories and supply
Veterinary Medicines Guidance Note 14 –
Marketing Authorization Exemption Scheme for Pet Animal Medicines