AUTH/3904/5/24: Complainant v Gedeon Richter (Evra ad and linked e-detail pages)

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Key facts

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Case number	AUTH/3904/5/24
Company	Gedeon Richter (UK) Ltd
Complainant	Contactable complainant (described themselves as a healthcare professional)
Product	Evra (norelgestromin/ethinyl estradiol) transdermal patch
Channel	Advertisement on a closed community professional network for doctors; linked e-detail aid website pages (‘Benefits’, ‘Safety & tolerability’)
Main allegations	Missing facets of indication; linked pages missing licensed indication and significant risks/contraindications; potential wider-than-licensed promotion; inadequate safety information
Applicable Code	2021
Clauses considered	2, 5.1, 6.1, 11.2
Panel decision	No breach of Clauses 2, 5.1, 6.1 (x2), 11.2 (x2)
Appeal	No appeal
Complaint received	15 May 2024
Case completed	4 June 2025

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

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A healthcare professional complained about an Evra (norelgestromin/ethinyl estradiol) promotional advertisement shown on a closed UK doctors’ network.
The complainant alleged the ad omitted “key facets” of the SmPC indication (including age range and VTE risk considerations) and therefore promoted to a wider audience than licensed.
The ad linked to an Evra e-detail aid website; the complainant alleged the linked ‘Benefits’ page did not state the licensed indication or “significant risks”.
The complainant also alleged the ‘Safety & tolerability’ page did not explicitly call out contraindications (SmPC section 4.3).
Gedeon Richter stated the prescribing information (PI) was available via a prominent single-click link from the ad and each webpage, and that a pop-up on the ‘Introducing EVRA’ page summarised warnings/precautions and contraindications with links to the SmPC.

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Clause 2 – Requirement that activities or materials must not bring discredit upon, or reduce confidence in, the pharmaceutical industry
Clause 5.1 – Requirement to maintain high standards at all times
Clause 6.1 (x2) – Requirement that information/ claims/ comparisons must not be misleading
Clause 11.2 (x2) – Requirement that a medicine must be promoted in accordance with the terms of its marketing authorisation and must not be inconsistent with the particulars listed in its summary of product characteristics

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