Vifor Ferinject website: open-access landing page promoted a POM to the public and “simple to administer” claim found misleading

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Key facts

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Case	AUTH/3303/1/20
Complainant	Anonymous, contactable individual
Company	Vifor Pharma UK
Material	Ferinject website (ferinject.co.uk), incl. landing page and HCP/patient sections
Medicine	Ferinject (ferric carboxymaltose)
Indication (as stated)	Treatment of iron deficiency when oral iron preparations were ineffective or could not be used
Applicable Code year	2019
Complaint received	23 January 2020
Case completed	3 August 2020
Appeal	No appeal
Breach clauses	7.2, 7.4, 9.1, 26.1, 28.1, 28.3
No breach clauses	2, 4.1, 4.9, 26.3
Sanctions	Undertaking received; Additional sanctions: Not stated

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

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An anonymous, contactable complainant challenged content on Vifor Pharma UK’s Ferinject (ferric carboxymaltose) website (ferinject.co.uk; refs incl. UK-FCM-1900320, September 2019).
The open-access landing page displayed the Ferinject brand logo and referenced treatment of iron deficiency/iron deficiency anaemia, and routed users to HCP, patient, or “neither” pathways.
The complainant alleged missing obligatory information (prescribing information and adverse event reporting) and that the landing page was promotional to the public.
The complainant also challenged an HCP claim that Ferinject was “easy/simple to administer” as misleading/unsubstantiated given the SPC administration requirements (e.g., trained staff, resuscitation facilities, monitoring, dilution/infusion steps).
A further allegation claimed wording about “Simplified dosing and administration for all patients” implied use in under-14s (contrary to SPC wording that use not studied/not recommended under 14).
Concerns were also raised about patient adverse event reporting statements and about signatory input/standards.

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Breach: The openly accessible landing page was considered promotional and promoted a prescription-only medicine to the public.
Breach: The HCP claim that Ferinject was “simple to administer” was misleading and could not be substantiated (Panel found Vifor’s justification addressed dose calculation, not administration complexity).
No breach: No breach for missing prescribing information/adverse event wording on the open-access landing page (Panel view: an open-access landing page should not be promotional; therefore HCP obligatory information was not required there).
No breach: Patient section had a “Side Effects” tab linking directly to a page with adverse event reporting information consistent with Clause 26.3 requirements.
No breach: HCP adverse event reporting wording was included within the “Prescribing Information” tab.
No breach: “Simplified dosing and administration for all patients” did not imply use in under-14s in context (homepage also stated “Licensed for ages 14 years and over” and the HCP section referenced adults).
Breach: Internet requirements breached due to the above findings (material for HCP/public on the internet must comply with relevant requirements).
Breach: High standards clause breached.
No breach: No breach of Clause 2 (Panel did not consider the circumstances warranted it).

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