2026 Cases
Case No. 306-06-26 Elanco AH UK Limited vs. Zoetis UK Limited
Case No. 306-06-26 was brought by Elanco AH UK Limited against Zoetis UK Limited regarding the promotional activities relating to Zenrelia®, a treatment for allergic dermatitis and atopic dermatitis in dogs. The Committee considered two areas (each with multiple allegations) of breaches of the NOAH Code of Practice for the Promotion of Animal Medicines, with the matter considered at a committee meeting held on the 19th of June 2026.
The items considered included:
Item 1: Allegation that Zoetis sales representatives made false statements that a treatment break from Zenrelia® is required before administering vaccinations, which is not supported by the UK SPC, alleged to be in breach of the following Clauses:
3.1 A Promotion must never be such as to bring discredit upon, or reduce confidence in, the animal medicines industry.
4.3 (iii) (A Promotion of Animal Medicines must) not be misleading (directly or by implication).
4.3 (iv) (A Promotion of Animal Medicines must) not directly or by implication disparage the products or services of other companies.
4.4 (i) (Any information or claim in a Promotion of Animal Medicines must) be accurate.
4.4 (ii) (Any information or claim in a Promotion of Animal Medicines must) be based on an up-to-date evaluation of all the evidence and must reflect this evidence accurately and clearly.
4.4 (iv) (Any information or claim in a Promotion of Animal Medicines must) not be inconsistent with the SPC, except that a Veterinary surgeon or other appropriately qualified person employed or engaged by a participating company may in appropriate circumstances give information about cascade use in response to a technical enquiry from another Veterinary Surgeon. Requests about cascade use posted on online forums must be responded to via a private message to the person requesting the information.
11.2 Representatives must at all times maintain a high standard of ethical conduct in the discharge of their duties.
Item 2: Allegation that Zoetis sales representatives made disparaging comparisons between Apoquel® and Zenrelia®, suggesting that Zenrelia® has an inferior safety profile, based on multiple reports from veterinary practices, alleged to be in breach of the following Clauses:
3.1 A Promotion must never be such as to bring discredit upon, or reduce confidence in, the animal medicines industry.
4.3 (iii) (A Promotion of Animal Medicines must) not be misleading (directly or by implication).
4.3 (iv) (A Promotion of Animal Medicines must) not directly or by implication disparage the products or services of other companies.
4.4 (vii) (Any information or claim in a Promotion of Animal Medicines must) not use any comparative safety information unless such is limited to information taken directly from the approved SPC or that obtained from a well-controlled clinical study of products and in either case must not be presented in a misleading manner. The use of Suspected Adverse Event data originating from regulatory authorities regarding other companies’ products is not permitted. The use of a Participant’s (or Marketing Authorisation Holder’s) own Suspected Adverse Event data is also not permitted.
11.2 Representatives must at all times maintain a high standard of ethical conduct in the discharge of their duties.
The Committee considered written submissions from both parties and heard detailed presentations at the meeting. Evidence included written reports from veterinary practices, which were anonymised but verified by the Committee Chair and Secretary.
Elanco presented their case to the Committee:
Elanco presented its case that Zoetis representatives were proactively sharing messages which contradicted the UK SPC for Zenrelia®, including statements relating to the need for a treatment break for vaccination. Elanco stated that the UK SPC confirms that there is no requirement for a treatment break and that promotion should be based on the relevant SPC. Elanco further explained that comparisons between products should not be based on the availability of data or the length of time a product has been on the market, as this would hinder innovation.
Elanco relied on four written reports from veterinary practices, noting that these had initially been raised verbally by the vets to Elanco representatives and were followed up in writing. Elanco stated that it is unusual for veterinary practices to provide written reports of this nature and that the reports came from different geographical areas. The veterinary practices retained anonymity throughout the case with only the Chair and Secretary being able to view unredacted submissions to review their veracity.
For Item 1, Elanco referred to a report from a veterinary surgeon describing a comment by a Zoetis representative regarding the need for a treatment break. Elanco stated that this issue was subsequently raised at a CPD event by the vet who had heard the comment and required correction by Elanco at the time. For Item 2, Elanco presented reports of vets hearing comments from Zoetis representatives in which Zenrelia® was described as being associated with anaemia, where Cytopoint® was suggested as an alternative, and where Zenrelia® was described as riskier due to the number of JAK receptors it inhibits. Elanco stated that they had evidence to prove that Zenrelia® does not represent greater risks to patient safety than Apoquel®, as demonstrated by a Head-to-Head study. Elanco emphasised that the NOAH Code does not permit companies to compare safety unless using information taken directly from the approved SPC or information from a well-controlled clinical study of products and no evidence was available indicating this to be the case.
Zoetis presented their response to the Committee:
Zoetis accepted that the Chair has verified the contents of the redacted reports, to protect identities (from veterinary practices) as received from Elanco and therefore these are accepted as being verified evidence. Zoetis also accept that the UK SPC for Zenrelia® contains no special warning for a treatment break with the vaccination.
Zoetis also noted that Elanco’s own promotions are targeted at and mention Zoetis products which will inevitably lead to comparative discussions of the products.
The Committee asked various questions about the extent of internal training on actively referring to how comparisons can be done. Zoetis confirmed the wording of this training and how this information is available to the account managers.
Zoetis reiterated that there were no head office communications on this issue, directing staff to promote Zenrelia® in this manner, that there is no systemic practice of doing so, and they do not feel that the evidence put forward can be fully investigated or substantiated. When asked, Zoetis also confirmed not being aware of any issues or complaints raised to them directly from vet practices about representative behaviour.
Committee decision:
For item 1, the Committee determined that any claim that a treatment break from Zenrelia® is required prior to vaccination is not supported by the UK SPC and constitutes a breach of the Code. The Committee considered it notable that a veterinary practice deemed it necessary to report its concerns and that the practice was willing to follow up with a report in writing, making the evidence compelling and assisting the Committee to determine it was proven. The Committee concluded that the promotional activity breached Clauses 4.3 (iii), 4.4 (i), 4.4 (ii), 4.4 (iv), and 11.2. No breach of Clauses 3.1 or 4.3 (iv) was found.
For item 2, the Committee considered four written reports alleging disparaging statements about the safety of Zenrelia®. Three of the reports were found to be proven, while one could not be substantiated due to insufficient detail. The Committee concluded that the proven activities breached Clauses 4.3 (iii), 4.3 (iv), 4.4 (vii), and 11.2 of the Code, with no breach of Clause 3.1 established.
In its additional commentary, the Committee noted that although Clause 3.1 was not breached, the conduct of Zoetis representatives came close to doing so. The Committee expressed concern that Zoetis had not fully acknowledged its breaches publicly and indicated that a public apology would have been appropriate given the seriousness of the allegations.
The Committee emphasised the responsibility of Zoetis, as with all NOAH members, to manage information about competing products carefully and to avoid making misleading or disparaging statements, particularly in light of the importance of maintaining high ethical standards and encouraging innovation within the animal health industry.
Following these findings, Zoetis UK Limited were issued with the following undertakings in relation to both items:
Case No. 306-06-26
- We acknowledge and accept the decision of the Committee in Case 306-06-26 as set out in the NOAH Code of Practice Decision Notice provided by email on the 26th of June 2026.
- We undertake that our representatives must not make any promotions or statements which refer directly or otherwise imply that a treatment break from Zenrelia® is required when administering vaccinations.
- We further undertake that our representatives must not make any promotions or statements which refer directly or otherwise imply that Zenrelia® has an inferior safety profile nor that its prescription incurs greater risk than Apoquel®.
- We hereby give an assurance that we will take all possible steps to avoid a breach of the above undertakings.