By: Emmanuela Yiannikakis
In the span of only a few years, GLP-1 weight-loss drugs such as Wegovy, Ozempic, and Mounjaro have become household names. Originally designed for diabetes, these drugs have redefined the global conversation around obesity treatment and, in the process, sparked an unprecedented surge in demand. According to a 2025 review, this surge is one of the primary drivers of ongoing global GLP-1 shortages. But that surge has come with a cost: shortages, inflated prices, and questions about whether direct-to-consumer (DTC) advertising has played too large a role in fueling the craze. The United States permits DTC prescription drug advertising, while the United Kingdom strictly prohibits it. This divergence offers a natural experiment in how advertising controls shape markets, access, and public health outcomes. Recent regulatory shifts in both countries—particularly the U.K.’s 2025 enforcement crackdown—reveal contrasting philosophies and shed light on whether advertising bans can temper runaway demand.
In the United States, the Food and Drug Administration (FDA) regulates prescription drug advertising under the “fair balance” rule, requiring that promotional materials present both benefits and risks in a non-misleading way. Advertisers must also provide a “brief summary” of side effects or “adequate provision” for consumers to access complete drug information. Yet these rules have long been criticized for allowing emotive imagery and lifestyle appeals that obscure risk information. In November 2023, the FDA issued a final rule tightening these standards by mandating that the “major statement” of side effects in television and radio ads be “clear, conspicuous, and neutral.” The new rule requires synchronized audio-text presentation, prohibits distracting visuals, and standardizes font and readability requirements for broadcast ads. Compliance became mandatory in late 2024, signaling a shift toward greater transparency in consumer drug marketing.
Still, the core structure of the American system remains permissive. The United States is one of only two countries in the world, along with New Zealand, that allows direct-to-consumer advertising of prescription medications. That openness has allowed GLP-1 manufacturers and telehealth companies to market aggressively through television, digital platforms, influencers, and discount programs. Nearly 13 percent of American adults have now used GLP-1 receptor agonists—a figure that underscores how deeply direct-to-consumer marketing has shaped public awareness and treatment demand. A 2025 article in the Richmond Public Interest Law Review argues that such pervasive promotion blurs the line between medical advice and advertising, eroding the traditional safeguards of physician oversight. When drug manufacturers speak directly to consumers, rather than through prescribing physicians, the learned intermediary doctrine begins to lose relevance, raising new questions about responsibility and patient protection in an era where marketing often drives medical decision-making.
The scale of U.S. advertising has coincided with steep price disparities and mounting affordability issues. A Business Insider analysis found that a month’s supply of semaglutide for weight loss costs roughly $804 in the United States, compared with about $257 in the United Kingdom—a threefold difference. Ozempic itself is estimated to be nearly ten times more expensive in the U.S. than in the U.K. These price gaps reflect the U.K.’s system of government-negotiated pricing and the U.S.’s fragmented market, but they also reveal how marketing and cost can reinforce one another. DTC advertising in the U.S. not only drives consumer demand but sustains high willingness to pay, giving manufacturers less incentive to lower prices. Similarly, Forbes has reported that the U.S. obesity drug market is far larger than Europe’s, partly because of aggressive promotional practices and the absence of centralized price controls. Together, these dynamics have created a self-perpetuating cycle: demand inflates prices, and prices, paradoxically, reinforce the allure of these drugs as premium, celebrity-endorsed products.
While American regulators have been reluctant to ban DTC advertising outright, the FDA and Congress have signaled growing unease. In September 2025, the FDA launched a crackdown on deceptive drug advertising, issuing removal orders for misleading claims related to telehealth and weight-loss services. Meanwhile, lawmakers have reintroduced the End Prescription Drug Ads Now Act, which would prohibit DTC prescription drug advertising nationwide. Yet such legislation faces steep constitutional hurdles. Courts have consistently recognized pharmaceutical ads as protected commercial speech under the First Amendment, limiting Congress’s ability to impose blanket bans. Legal analysts, including commentators at Brownstein Hyatt Farber Schreck, note that only false or misleading ads can be curtailed outright, leaving much of the industry’s persuasive promotional speech protected.
The United Kingdom’s regulatory philosophy exemplifies a sharp contrast. Under the Human Medicines Regulations 2012, as amended by the Human Medicines (Amendments Relating to the Windsor Framework) Regulations 2024, advertising prescription-only medicines (POMs) to the public remains strictly prohibited. Oversight is shared between the Medicines and Healthcare products Regulatory Agency (MHRA), which enforces statutory restrictions; the Advertising Standards Authority (ASA), which monitors digital and social media marketing; and the Prescription Medicines Code of Practice Authority (PMCPA), which administers the ABPI Code of Practice for the Pharmaceutical Industry 2024. Whereas the U.S. system focuses on maintaining “fair balance” and disclosure standards, the U.K. model forbids direct-to-consumer prescription drug advertising altogether, reflecting a public health philosophy that prioritizes professional consulting over consumer persuasion.
That approach, however, has faced new tests in the era of social media and influencer marketing. In 2024 and 2025, British regulators observed a surge in online posts from wellness clinics and pharmacies promoting “weight-loss injections” or showing images of GLP-1 pens without explicitly naming a drug. In response, the MHRA issued a series of enforcement actions in September 2025 directing companies to amend or remove such advertisements. The ASA followed with an updated enforcement notice warning that any direct or indirect reference to GLP-1 products in public-facing promotions would violate U.K. law. By mid-2025, the ASA had banned multiple online pharmacy ads and influencer posts for breaching these rules, underscoring a new willingness to police digital channels. The Guardian reported that even references to “skinny pens” and other coded language were deemed unacceptable, prompting online clinics to scrub their marketing materials.
Despite these efforts, challenges remain. Many British companies continue to exploit gray areas by advertising “weight-loss programs” that bundle consultations with the eventual prescription of GLP-1 drugs. The MHRA and ASA have acknowledged that while such “service marketing” does not always explicitly violate the ban, it undermines its spirit. Enforcement resources are also limited: although the MHRA possesses authority to impose fines or pursue criminal sanctions, it typically relies on voluntary compliance and corrective orders rather than prosecution. Nonetheless, the stepped-up 2025 campaign has significantly reduced the visibility of consumer-facing GLP-1 promotions across U.K. media.
In contrast, the United States remains uniquely exposed to promotional amplification because DTC prescription advertising is still legal. The FDA continues to confront the downstream consequences of aggressive marketing: persistent off-label interest, counterfeit and compounded semaglutide sales, and uneven consumer understanding of drug risks. Even after the February 2025 resolution of official Ozempic and Wegovy shortages, the agency warned of unapproved compounded products circulating online. The United States’ permissive DTC advertising landscape continues to shape consumer expectations and market dynamics in ways that regulators struggle to contain. The result is a self-reinforcing cycle: marketing drives awareness and demand, which heightens supply pressure and regulatory risk—a pattern largely avoided in the U.K. due to its comprehensive advertising ban and professional gatekeeping framework.
The lessons for policymakers are complex. The U.S. model, rooted in transparency and individual choice, assumes that informed consumers can weigh risks and benefits when presented fairly. But the GLP-1 experience shows that advertising is not a neutral information tool: it shapes perceptions of health, normalcy, and urgency in ways that drive utilization. The U.K. model, by contrast, treats prescription drug marketing as a matter for professional gatekeepers, preserving physician control over prescribing decisions. While that approach dampens consumer demand, it also limits patient awareness and potentially slows uptake of legitimate treatments.
Ultimately, both systems reveal the trade-offs between information and influence. In the United States, DTC advertising has amplified public enthusiasm for GLP-1 drugs but has also contributed to shortages, inflated prices, and blurred the boundaries of medical oversight. In the United Kingdom, a strict advertising ban and recent enforcement actions have constrained marketing-driven demand but cannot fully insulate the market from global dynamics. The experience of these two countries suggests that advertising policy is more than a question of speech—it is a determinant of public health outcomes. In the end, the transatlantic contrast shows that the line between informing and influencing is not just regulatory—it is profoundly public-health-defining.
