AUTH/3108/10/18: Mitsubishi Tanabe Pharma Europe – product webpages held to promote POMs to the public

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Key facts

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Case number	AUTH/3108/10/18
Company	Mitsubishi Tanabe Pharma Europe
Material/channel	Company website product pages (internet)
Products mentioned	Exembol (argatroban); Tanatril (imidapril)
Main issue	Promotion of POMs to the public; unclear audience separation and insufficient access restriction
Complaint received	29 October 2018
Case completed	20 February 2019
Applicable Code year	2016
Breach clauses	9.1; 26.1; 28.1
No breach clauses	2
Appeal	No appeal
Sanctions	Undertaking received; Additional sanctions: Not stated

Reviewed by Dr Anzal Qurbain (FFPM) — ABPI Final Signatory

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A UK health professional complained that Mitsubishi Tanabe Pharma Europe’s corporate website product pages effectively promoted prescription-only medicines (POMs) to the public.
The products referenced were Exembol (argatroban) and Tanatril (imidapril).
The complainant alleged there was no clear patient area and that selecting “read more” exposed brand/generic names and indications to the general public.
The product pages included statements about argatroban (including “first licensed synthetic direct thrombin inhibitor” and “Approved in twelve European countries”) and Tanatril (use in hypertension, ACE inhibitor class, available strengths).
Pages carried a small-font note: “Please note: certain pages are intended for healthcare professionals only”, but did not identify which pages were HCP-only or clearly separate public vs HCP content.
For Exembol (UK), a pop-up asked users to confirm they were UK health professionals before accessing links to the SPC/PIL; however, the upstream product pages containing names/indications/claims were accessible without restriction.
The Tanatril “read more” page was titled “How to order Tanatril” and included wholesaler ordering details and PIP codes, plus links to SPC/PIL.

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Breach of Clause 26.1 (promotion of POMs to the public) in relation to the product webpages.
Breach of Clause 28.1 (internet material: where promotional POM content is accessible, access must be restricted or public/HCP sections clearly separated with intended audience identified).
Breach of Clause 9.1 (failure to maintain high standards).
No breach of Clause 2 (Panel did not consider the circumstances warranted particular censure).
No appeal.

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