Clients often ask us to review national marketing campaigns in
relation to over-the-counter drug and natural health products
(NHPs). In doing so, we must advise clients of the
differences in marketing strategies they need to undertake in the
province of Quebec as compared to other provinces.
Under their professional Code of ethics1, Quebec pharmacists are not allowed
to engage in activities that promote the consumption of drugs. As
such, pharmacists cannot promote contests, give rebates, discounts,
gifts or redeem coupons on medication. The prohibition is clear
with respect to drugs that one would normally associate with the
term "medication" (i.e. scheduled drugs that can
only be sold in pharmacies), but what about NHPs or unscheduled
drugs like sunscreens and dandruff shampoos?
The term "medication" is defined broadly enough in the
Pharmacy Act to include NHPs and unscheduled drugs.
Accordingly, the prohibition on promotion would likely apply to
these products. But that is not the end of the story.
In Quebec, pharmacy ownership restrictions also limit who may
own and operate a pharmacy. These ownership and marketing
restrictions explain the strategic approach of well known
"pharmacy" chains to organize in part as retail
store chains (franchisor and wholesaler only relationship) - so
that not all product sales come under the Pharmacy Act.
For this reason, Quebec retail pharmacies are most often
physically divided into two sections: (1) a professional section
– which sells the scheduled products, and (2) a commercial
section – where it can sell any other product, similar to a
general retail store. It also explains the presence of glass doors
all around the over-the-counter section - those are mandatory in
Quebec, as technically, only the professional section is a
pharmacy. It is also interesting to note that "pharmacy"
chain flyers are also physically divided into professional and
commercial sections (and are positioned as two different
So in the end, despite the general prohibition, it can be
appropriate to promote NHPs and unscheduled drugs using contests,
rebates or coupons in Quebec as long as these promotions are only
located in the commercial section of advertising materials and
redeemed in the commercial section of the pharmacy.
1. Code of ethics of pharmacists, RRQ, c P-10, r 7 s
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