A heady brew

Can pharmacies really promote “vaccines, beer and nicotine” all at once under new TGA authorisations?

Pharmacies can offer alcohol as an incentive while also promoting COVID-19 vaccination and the availability of nicotine e-cigarettes, but only under certain “strict” conditions for each offering, according to the Department of Health and a medicines advertising expert.

“Pharmacy can now promote vaccines, beer and nicotine,” news outlet PharmaDispatch recently reported.

It continued that community pharmacies participating in the COVID-19 vaccination program will be able to “promote a local pub to the fully vaccinated while advertising the availability of nicotine e-cigarettes” under authorisations granted by the TGA.

AJP has followed up the claims to find out what pharmacists need to know about the changes.

Pharmacist Emi Gosling, a specialist provider of regulatory guidance on the advertising of therapeutic goods, medicines and health professional services pointed out that originally, “Australian businesses were given the go-ahead to offer incentives for vaccination, on the proviso that the reward did not include tobacco, medicines (other than listed) or alcohol.

“Although given our love for a refreshing drink, and with the backing of our own Prime Minister, the TGA subsequently revised the position allowing ‘common sense’ to prevail – free beer is back on the cards,” Ms Gosling told AJP.

The permission that allows the advertising of approved COVID-19 vaccines allows any party including pharmacies to offer incentives to people who have been fully vaccinated for COVID-19, according to the Department of Health.

This includes alcohol, however the offer of tobacco or medicines (other than listed medicines) as an incentive is prohibited.

The Department of Health said that, “The permission makes it clear that an offer of alcohol must not encourage excessive or rapid consumption of alcohol; must not have a strong or evident appeal to minors; and must be served consistent with the Responsible Service of Alcohol arrangements.

“These conditions ensure that offers of alcohol will not encourage excessive alcohol intake, while allowing Australian businesses to encourage the uptake of COVID-19 vaccination by eligible Australians,” the Department told AJP.

Pharmacies are able to offer incentives to individuals who are fully vaccinated provided the requirements of the permission are met, said Ms Gosling.

For example, incentives can only be offered for COVID-19 vaccines that are approved by the TGA for use in Australia.

They must not contain any reference to trade names or active ingredients (e.g. mRNA), and must make it clear that vaccination must be undertaken on the advice of a health practitioner.

Incentive is available to individuals who are fully vaccinated, i.e. they have had two doses within applicable timeframe – although a directive on how this is to be demonstrated has not made, she said.

“In addition to these requirements, pharmacists should be mindful of the National Law, enforced by AHPRA that adds another layer of complication to advertising vaccination services,” emphasises Ms Gosling.

“Health professionals are not permitted to advertise a registered health service in a manner that offers a gift, discount or other inducement to attract a person to use the service or the business, unless the advertisement also states the terms and conditions of the offer,” she said.

“Unusually for therapeutic goods, healthcare professional endorsement of COVID-19 vaccines is permitted, and further the permission allows for these S4 medicines to be promoted to the public – encouraging the use and supply.”

Advertising cannot compare vaccines available, call them out by identifiable name or brand, or suggest they are “safe”.

Meanwhile recent changes mean that although advertising of nicotine vaping products is technically prohibited, pharmacies are now allowed to do so “within certain and strict conditions”, said the Department of Health.

“In Australia, nicotine vaping products for smoking cessation are regulated as prescription medicines, as such, the advertising of these products to consumers is prohibited,” the Department told AJP.

“To facilitate necessary communications about the availability of nicotine vaping products to enable patients to fill prescriptions, the TGA issued a legal permission which allows pharmacies and pharmacy marketing groups to indicate that they can supply nicotine vaping products for smoking cessation on presentation of a valid prescription, subject to strict conditions,” said the Department.

“The permission limits the advertising of nicotine vaping products to information necessary to convey the location at which the nicotine vaping products are available, the kinds and forms of nicotine vaping products available and the concentrations.

“Widespread advertising is not facilitated by the permission, with advertising restricted to certain channels only.”

For pharmacies looking for more information, the TGA has published guidance to explain limits on how COVID-19 vaccines should be promoted.

“If you’re thinking of offering an incentive to vaccinated and wish to advertise, go for it!” Ms Gosling said.

Offers can be made to a certain group, for example the employees of the business, or the members of the organisation, or to all members of the public. So far the promotional period runs from 10 July 2021 until 31 December 2022.

However with government health messaging constantly evolving, she encouraged pharmacies to keep up-to-date with the latest materials.

So there you have it: technically, yes, pharmacy can now promote COVID-19 vaccines, offer beer as an incentive to the fully vaccinated, and advertise the availability of nicotine e-cigarettes all at the same time. But there are careful rules for each offering that pharmacies need to follow to ensure all is above board.

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1 Comment

  1. Ken Harvey

    One wonders how many people will be encouraged to get two shots of a COVID-19 vaccine so they can get a free beer? Are we now going to see drinkers embarking on free, government-endorsed, pub crawls of establishments offering alcohol vaccination rewards?

    Also, is the focus on individual benefit is the right approach? It’s interesting to contrast the government’s advertising focus on individuals (Arm yourself) with other advertising (Message from Victoria) that focuses on community benefit. See: https://youtu.be/DTUfHhOmJN0 and compare with https://youtu.be/fDfug35d5fU.

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