Retail of veterinary medicinal products at a distance is permitted across the EU, but on defined terms. Article 104 of Regulation (EU) 2019/6 sets the conditions, and Commission Implementing Regulation (EU) 2021/1904 established the design of the common logo that lawful online retailers must display. Applicable since 28 January 2022, the logo is the consumer-facing signal that separates a permitted retailer from an illegal one.
What may be sold at a distance
Article 104 allows online sale of veterinary medicinal products that are not subject to prescription, including between Member States. Prescription-only products are treated differently, and national rules remain relevant to how retail is authorised and supervised. Article 103 covers retail generally and the record-keeping obligations attached to it.
The common logo
Article 104(7) provides for a common logo, whose design is set out in Implementing Regulation (EU) 2021/1904. Its function is to vouch for the authenticity of the website and give the purchaser confidence in the product. The mechanics matter:
- The logo must be displayed on every page of the website of a retailer permitted to offer veterinary medicines for sale at a distance.
- It must carry a hyperlink to the list, maintained by the competent authority of the relevant Member State, of retailers established there and permitted to sell at a distance.
- That link is what makes the logo verifiable. A logo image without a working link to the authority’s list tells a purchaser nothing.
Why marketing authorisation holders should care
Retail compliance is the retailer’s duty, not the holder’s. But the consequences of a weak online channel land on the product. Counterfeit and diverted stock reaches animal keepers through unlisted websites. Products appear on sites outside the markets where they are authorised, with product information in the wrong language or no product information at all. Prescription-only products are offered without prescription. Each of these is a product quality and safety issue expressed as a channel problem.
Holders that monitor their own products online, verify that their authorised distributors display the logo correctly, and report unlisted sellers to the competent authority are protecting their own authorisation as much as the consumer.
Practical checks
- Confirm which of your products are prescription-only in each market, because the classification determines whether distance retail is lawful at all.
- Check that distributors selling your products online appear on the relevant competent authority list.
- Verify that the logo on those sites links to the authority list rather than being a static image.
- Monitor for offers of your products on sites that appear nowhere on any national list.
- Make sure product information available online matches the authorised text for that market.
How PQRA helps
PQRA advises animal health companies on distribution and retail compliance for veterinary medicines in Greece and across the EU, including prescription classification, distributor oversight, online channel review, and engagement with competent authorities where unlawful supply is identified.
To review your veterinary distribution and online channel, contact PQRA.
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