Most conversations about the Uniform Code for Pharmaceutical Marketing Practices (UCPMP) 2024 are about doctors: gifts, travel, conferences and samples. But the code’s first clause defines promotion as all informational and persuasive activities whose effect is to induce the prescription, supply, purchase or use of a medicine. That includes your website, your product list PDF, your Instagram posts and the WhatsApp creatives your franchise partners forward.
This guide goes through the clauses that matter for a pharma company’s online presence, especially for PCD franchise companies and third-party manufacturers, and ends with a checklist you can run against your own site.
This is a practical summary, not legal advice. The full text is on the Department of Pharmaceuticals website; check it, and your association’s guidance, before acting on anything here.
What UCPMP 2024 is
The Department of Pharmaceuticals notified UCPMP 2024 on 12 March 2024, replacing the 2015 code. It has 14 sections covering claims, promotional material, medical representatives, brand reminders and samples, CME, research, relationships with healthcare professionals, and a complaints process run by industry associations with an appeal to the Department.
Two things make it more than a guideline you can file away:
- The CEO is personally on the hook. The executive head of every company must submit a self-declaration of compliance within two months of the end of each financial year (clause 14.4).
- Anyone can complain. A complaint can be filed against any company, member of an association or not, and the outcome is published (sections 9–13).
According to industry reports, the code was further amended in September 2025, including a requirement for companies to file annual statements of marketing expenditure online. Check the Department’s UCPMP portal for the current standing orders.
1. Promote only what is approved
Clause 1.2 says a drug must not be promoted before it receives marketing approval, and its promotion must be consistent with the terms of that approval.
On a website, that means:
- No product pages for products you don’t yet have a licence for. A “launching soon” page with indications counts as promotion.
- Indications must match the approval. If a product page lists uses beyond what the product is approved for, often copied from another brand’s page or a molecule’s Wikipedia entry, that is a breach.
- Information must be balanced, up to date and verifiable (clause 1.3), and you must be able to substantiate it on request from healthcare and pharmacy professionals.
2. The words you can’t use loosely
Clause 2 has the rules most pharma websites break without noticing.
“Safe.” It must not be used without qualification, and you can’t state categorically that a medicine has no side effects, toxic hazards or risk of addiction (clause 2.2). Phrases like “100% safe”, “no side effects” and “completely natural, zero side effects” (common on ayurvedic and nutraceutical pages) are exactly what this clause targets.
“New.” A drug that has been generally available, or a therapy generally promoted in India, for more than a year can’t be called new (clause 2.3). Old “New launch!” banners and “new products” sections that never change are the usual problems.
Claims of usefulness must be based on an up-to-date evaluation of all the evidence (clause 2.1), not on the best study you could find.
3. Comparisons and competitors
- Comparisons must be factual, fair and capable of substantiation, and must not mislead through distortion, undue emphasis or omission (clause 2.4).
- You can’t name another company’s brand in a comparison without that company’s prior consent (clause 2.5). “Same composition as [competitor brand], at half the price” is a breach unless the competitor agreed.
- You can’t disparage other companies, their products or services, directly or by implication (clause 2.6). “Unlike other PCD companies, our products actually work” crosses the line.
This also applies to SEO pages. Pages built to rank for a competitor’s brand name, comparing your product to theirs, are promotional material under the code.
4. What a product page must include
When promotional material is meant to give prescribers enough information to decide whether to prescribe, clause 3.2 requires, as an integral part of it:
- The name and address of the company holding the authorisation (or marketing the product)
- The brand name with the active ingredients by generic name, right next to the most prominent display of the brand name
- Recommended dosage and method of use
- Adverse reactions, warnings, precautions and contraindications
- A statement that more information is available on request, and the date the information was produced or last updated
Clause 3.8 adds that informative material should state its date of printing or last review.
For a PCD catalogue, the practical version is: show the composition beside every brand name (you should be doing this for SEO anyway), put prescribing information on detailed product pages or link to it, and show a “last reviewed” date on product pages and product list PDFs.
5. Doctors’ names and photos
Clause 3.6 is short: the names or photographs of healthcare professionals must not be used in promotional material.
This is one of the most commonly broken rules online:
- “What doctors say about us” testimonials with names and photos
- Instagram posts of a doctor holding your product
- Event galleries showing doctors at a product launch
Testimonials from distributors and franchise partners about your service are a different matter; testimonials from doctors about your medicines are not.
6. Audience: professionals, not the public
The code is written for promotion to healthcare professionals. Mailings and anything publicly visible must not carry matter that could be regarded as advertising to the lay public (clause 3.9), and audio-visual material, such as YouTube videos and reels, must be backed by printed material that meets the code (clause 3.10).
Indian drug law goes further. The Drugs and Magic Remedies (Objectionable Advertisements) Act, 1954 bans advertisements claiming to diagnose, cure or prevent the diseases in its Schedule, and misleading claims about any drug. The drug rules also restrict how prescription medicines can be advertised to the public. A PCD website should therefore be written for distributors and healthcare professionals: product information, franchise terms and certifications, not health advice or treatment claims aimed at patients.
7. Franchise promotions: samples, gifts and “doctor schemes”
Many PCD franchise pages list the promotional support partners get. Some of what appears on those lists is now a problem.
Gifts. No gift, pecuniary advantage or benefit in kind may be given to a healthcare professional or their family, by a company or its agents, which the code names as distributors, wholesalers and retailers (clause 8.1). Travel, hospitality and cash are banned too, except travel and hospitality for speakers at CME programmes (clauses 8.2–8.4). A franchise page that promises “doctor gifts”, “doctor schemes” or “tour packages for doctors” advertises a breach, and your franchise partners are treated as your agents.
What is allowed. Informational and educational brand reminders, such as books, calendars, diaries, journals, dummy device models and clinical guidelines, worth up to ₹1,000 per item and with no independent commercial value (clause 5.1). Visual aids, product literature, reminder cards and MR bags for your partners’ teams are not gifts to doctors.
Samples. Free samples can only go to people qualified to prescribe the product, handed over directly, with records kept (clause 5.1). Each sample pack covers no more than three patients’ course of treatment, no company may give more than twelve sample packs per drug to a practitioner in a year, each pack must be marked “free medical sample, not for sale” and be no larger than the smallest marketed pack, and the total value of samples can’t exceed 2% of the company’s domestic sales a year. Hypnotics, sedatives and tranquillisers can’t be sampled at all. A “Request free samples” form open to anyone on your website doesn’t fit these rules.
Your partners’ material. Companies are responsible for their medical representatives, including contract staff (clause 4.4), and third parties working on their behalf should know the code (clause 4.5). If you hand franchise partners social media creatives, those creatives need to follow the code as much as your own website does.
8. One thing your website must publish
If your company conducts CME or CPD events, the code says you should share the details of those events, including the expenditure, on your website (clause 6.2). Events in foreign locations are not allowed.
What happens if someone complains
- Complaints go to the Ethics Committee for Pharma Marketing Practices (ECPMP) of the relevant industry association, in writing, with a ₹1,000 fee, within six months of the breach (extendable by six months with reasons). Anonymous complaints aren’t accepted (section 10).
- The company has 30 days to respond, and the committee should decide within 90 days (clauses 11.5–11.7).
- Possible outcomes include suspension or expulsion from the association, a published reprimand, a corrective statement in the same media used for the original promotion (which, for a website breach, means your website), recovery of money or items given in violation, and referral to the relevant government authority (section 12).
- Either side can appeal to the Apex Committee for Pharma Marketing Practices, headed by the Secretary of the Department of Pharmaceuticals, within 15 days (section 13).
- Associations publish complaint details on their websites for five years (clause 9.5), and that page is visible to the same distributors you are trying to sign up.
A 15-minute check of your own website
Open your site and look for:
- “Safe”, “100% safe” or “no side effects” anywhere, without qualification
- “New” on products that have been on the market for over a year
- Indications on product pages that go beyond the product’s approval
- Brand names without the generic composition right next to them
- Product pages or PDFs with no “last reviewed” date
- Other companies’ brand names, or comparisons with them
- Names or photos of doctors: testimonials, galleries, social posts
- “Doctor gifts”, “doctor schemes” or travel offers in your franchise promotional support
- A free-sample offer open to anyone
- Health advice or treatment claims aimed at patients
- Cure or prevention claims for serious diseases
- CME events you ran that aren’t disclosed on the site
If you find several, fix the product pages and franchise page first: they are the most visible to distributors and to anyone looking for a reason to complain.
How we handle this
When we build a PCD pharma franchise website or write content for pharma SEO, we write product and franchise pages for distributors and professionals, avoid the claims above, show composition beside every brand, and date product information. Your regulatory or medical team approves product content before it goes live.
If you’d like a second pair of eyes on your current site, send us the address and we’ll point out anything on this list that needs attention.