AstraZeneca breached Code over Trixeo website mobile display and missing comparator prescribing information (AUTH/3488/3/21)

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Key facts

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Case	AUTH/3488/3/21
Company	AstraZeneca UK Limited
Product/material	Trixeo Aerosphere website (www.trixeo.co.uk) and downloadable Trixeo formulary pack
Therapy area	Chronic obstructive pulmonary disease (COPD)
Complainant	Anonymous, contactable complainant
Complaint received	10 March 2021
Case completed	29 September 2021
Applicable Code year	2019
Appeal	No appeal
Breach clauses	4.1, 4.3, 4.4, 9.1, 14.1
No breach clauses	2, 4.3, 7.2, 7.4, 7.9, 7.10, 9.1, 9.7, 26.1, 26.2, 28.1
Sanctions	Undertaking received; additional sanctions not stated
Core issue(s) upheld	Mobile display not properly certified; non-proprietary name not readily readable on mobile; PI not one-click on mobile; missing PI for AZ comparator products mentioned (Bevespi, Symbicort) on website and in formulary pack

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

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An anonymous complainant challenged AstraZeneca’s UK promotional website for Trixeo Aerosphere (www.trixeo.co.uk) and a downloadable Trixeo formulary pack.
Allegations included: public access (no HCP gating), non-proprietary name too small, prescribing information (PI) not easily accessible on mobile, misleading efficacy/safety claims (relative vs absolute risk; “prevent exacerbations”; “Protection you can count on”; “A well-established safety profile”), use of capitalisation, and a dragon image implying special properties.
AstraZeneca said the site was intended for UK health professionals with an HCP declaration pop-up and footer notice; it took the site down after the complaint to address mobile-display issues.
AstraZeneca acknowledged technical/certification failures affecting mobile view: (1) generic name difficult to read on mobile, (2) PI required two clicks on mobile, and (3) the mobile view had not been certified.
The website and formulary pack referenced comparator arms in ETHOS/KRONOS using non-proprietary names for budesonide/formoterol (Symbicort) and glycopyrrolate/formoterol (Bevespi); PI for those products was not provided.

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No breach found for alleged promotion to the public (complainant did not establish, on the balance of probabilities, that the website constituted promotion to the public).
Breach for non-proprietary name readability on mobile devices.
Breach for PI not being accessible via a single click on mobile devices.
Breach for failure to certify the website for mobile viewing (final form differed from certified view).
Breach for missing PI for AstraZeneca comparator products (Bevespi Aerosphere and Symbicort Turbohaler) mentioned on the website and in the downloadable formulary pack.
No breach for the challenged claims/images (including “Unleash protection from exacerbations with Trixeo”, relative/absolute risk presentation, “You can prevent exacerbations”, “Protection you can count on”, “A well-established safety profile”, capitalisation/font, and the dragon image).
No breach of Clause 2 (Panel did not consider the circumstances warranted that level of censure).

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