Pharmacy guide

Advertising health services: what pharmacies may say – and what they may not

Reviewed by Dr. Daniel Wallerstorfer, molecular biologist and founder of Novogenia · Updated: 13 October 2026 · Reading time: 10 min

In short

In a pharmacy, every word carries extra weight because a health professional is speaking. For food supplements, only authorized health claims are allowed (Art. 10(1) Regulation (EC) No 1924/2006), such as “Magnesium contributes to a reduction of tiredness and fatigue” from Regulation (EU) No 432/2012. Disease references are prohibited for foods (Art. 7(3) Regulation (EU) No 1169/2011). Genetic analyses as a service fall under unfair competition law, and in Germany also under the Therapeutic Products Advertising Act as soon as the advertising refers to diseases (Section 1(1) No. 2 HWG). In Austria, the ABO 2005 prohibits sensationalist conduct and intrusive advertising by pharmacists (Section 1(6)). Switzerland has its own list of authorized claims (Annex 14 LIV) and mandatory information for genetic-test advertising (Art. 14 GUMG). The rule of thumb: describe what you offer – do not promise an effect.

The pharmacy as an amplifier

Austria’s Pharmacy Operations Ordinance contains a rule that any pharmacy could hang in its window: pharmacists may neither act in a sensationalist manner nor advertise intrusively (Section 1(6) ABO 2005).

The reason is obvious. Your pharmacy works like an amplifier: whatever is said at the counter, customers hear with the trust they place in a health professional. Good information comes across more clearly – but an exaggeration also sounds louder. If you offer personalized health, you win with factual, honest language. This article shows you the rules for genetic analyses, food supplements and cosmetics in Germany, Austria and Switzerland. It does not replace legal advice in the individual case.

Which rules apply to which offer

A personalized offer mixes service and product. Each element has its own guardrails:

What you advertise	Which rules apply	The key question
Food supplements	Regulation (EC) No 1924/2006, Art. 7 Regulation (EU) No 1169/2011; in Switzerland LMG, LGV and LIV	Is the claim authorized, and are its conditions met?
Genetic analysis as a service	Unfair competition law; in Germany the HWG if diseases are referred to; in Switzerland Art. 14 GUMG	Lifestyle or medicine – and is the promise true?
Cosmetics	Art. 20 Regulation (EC) No 1223/2009 with Regulation (EU) No 655/2013	Does the statement describe a cosmetic function that is supported by evidence?
Pharmacy and counseling	Unfair competition law; in Austria also Section 1(6) ABO 2005	Is the presentation factual and not intrusive?

Food supplements: the wording counts

A health claim is any claim that states, suggests or implies that a relationship exists between a food or one of its constituents and health (Art. 2(2)(5) Regulation (EC) No 1924/2006). Such claims are prohibited unless they are authorized and included in the list of authorized claims (Art. 10(1)). The list is set out in Regulation (EU) No 432/2012. Three examples in their official wording:

“Magnesium contributes to a reduction of tiredness and fatigue.”
“Vitamin D contributes to the normal function of the immune system.”
“Zinc contributes to the maintenance of normal skin.”

Each of these claims may only be used for food that is at least a source of the nutrient as defined in Regulation (EC) No 1924/2006. Mandatory information comes on top, such as a statement on the importance of a varied and balanced diet and a healthy lifestyle (Art. 10(2)). General statements like “good for your well-being” are only allowed when accompanied by a specific authorized claim (Art. 10(3)).

Two prohibitions hit pharmacies in particular:

Recommendations: Claims that make reference to recommendations of individual doctors or health professionals are not allowed (Art. 12(c)). Your counseling is fine – a poster saying “Recommended by pharmacist X” next to a health claim should be checked legally first.
Diseases: Food information must not attribute to any food the property of preventing, treating or curing a human disease – this also applies to advertising and presentation, down to the way products are arranged and the setting in which they are displayed (Art. 7(3) and (4) Regulation (EU) No 1169/2011; in Austria likewise Section 5(3) LMSVG). A shelf of supplements next to medicines for the same complaints can create exactly that impression.

How to find authorized claims and phrase them correctly is shown in Health claims: what you may advertise.

Advertising genetic analyses: a service, not a diagnosis

The genetic analysis itself is governed not by food law but mainly by unfair competition law. In Germany, advertising is misleading if it contains untrue or otherwise deceptive information, among other things about the results to be expected from use (Section 5(2) No. 1 UWG). Falsely claiming that a product or service can cure diseases is always prohibited (Annex No. 17 UWG; in Austria Annex No. 17 of the UWG).

As soon as your advertising refers to recognizing, eliminating or alleviating diseases, Germany’s Therapeutic Products Advertising Act (HWG) applies as well (Section 1(1) No. 2(a) HWG); for medical devices, including in vitro diagnostics, it applies anyway (No. 1a). It is then misleading, for example, to attribute effects to procedures that they do not have, or to falsely create the impression that success can be expected with certainty (Section 3 HWG). And a lifestyle analysis advertised as early disease detection no longer fits an offer without a medical purpose – see Law: what pharmacies must consider.

What you can say about genetic analyses

The most honest advertising is also the most convincing. These principles carry you through flyers, website and counseling:

Describe, don’t promise: “The analysis shows how your body processes, for example, caffeine, lactose or folate” – not “Finally find out what you’re missing.”
Separate evidence from conclusions: The genetic traits are well documented; recommendations derived from them are logical conclusions, not scientifically proven. Novogenia’s standard note says exactly that.
Put genes in context: Genes are one factor among many – diet, exercise, sleep and stress matter just as much.
Report, not finding: Lifestyle analyses deliver a report. Medical questions belong with a physician.
Pharmacogenetics only where permitted: Advertise it only in a country where your pharmacy may lawfully offer it. In Germany, it is a physician’s task (Section 3 No. 7(c), Section 7 GenDG).

What your team says on the phone, in the shop window or on social media is advertising, too. Give everyone a list of permitted phrases – how is shown in Training the pharmacy team. More examples: Advertising genetic tests.

Cosmetics: the language of care, not of medicine

For cosmetics, labeling and advertising must not imply characteristics or functions the product does not have (Art. 20(1) Regulation (EC) No 1223/2009). Regulation (EU) No 655/2013 sets six common criteria: legal compliance, truthfulness, evidential support, honesty, fairness and informed decision-making. In Germany, the HWG comes into play as soon as cosmetics advertising refers to diseases (Section 1(1) No. 2 with (2) HWG). So talk about care, moisture and how the skin feels – not about healing. Details in Advertising cosmetics.

Switzerland: its own list, its own mandatory information

Switzerland follows similar principles, but with its own law:

Food supplements: Information about foods must be true, and advertising must not deceive (Art. 18 LMG). Health claims are only allowed if provided for in Annex 14 of the LIV; others need authorization from the Federal Food Safety and Veterinary Office (FSVO) (Art. 31(2) and (3) LIV). Prohibited are references to preventing, treating or curing diseases and presentations that give a food the appearance of a therapeutic product (Art. 12(2)(c) and (d) LGV) – a point pharmacies should watch closely.
Genetic tests: Public advertising for tests in the medical field is prohibited, except for persons authorized to initiate them under Art. 20 (Art. 14(1) and (2) GUMG); their advertising must be objective and neither misleading nor intrusive (Art. 4(1) GUMV). Advertising for lifestyle analyses informs about the rules on initiation, information and communication of results (Art. 14(3) GUMG, Art. 4(2) GUMV) – for example, that the pharmacist initiates the analysis and the sample is taken in her presence.
Therapeutic products law: The HMG applies to medicinal products and medical devices (Art. 2(1)(a)); its advertising rules concern medicinal products (Art. 31 and 32). For lifestyle analyses and supplements, the GUMG and food law are the basis, and for services the ban on misleading information (Art. 3(1)(b) UWG).

Do’s and don’ts: phrases for the pharmacy

The examples are general. Check every statement for your offer and your country.

Do	Don’t	Why
“Magnesium contributes to a reduction of tiredness and fatigue.” (product is at least a source of magnesium)	“Never tired again – thanks to your gene blend.”	Only authorized claims with the same meaning (Art. 10(1) Reg. 1924/2006)
“The analysis shows how your body processes nutrients.”	“Our genetic test detects diseases before they develop.”	Disease reference: HWG (Section 1(1) No. 2) and medical purpose
“We draw logical conclusions from your genes for your nutrients.”	“Guaranteed the right dose for you.”	Promise of success; misleading (Section 5(2) No. 1 UWG; Art. 7(1)(b) Reg. 1169/2011)
Counseling in conversation, health claim without reference to a person	“Recommended by pharmacist Dr. X” next to a health claim	Reference to a health professional’s recommendation (Art. 12(c) Reg. 1924/2006)
Supplements presented as foods	A “Help for colds” shelf stocked with supplements	Disease reference, including through presentation (Art. 7(3) and (4) Reg. 1169/2011)
“Cares for and moisturizes the skin.” (if supported)	“Heals eczema.”	Cosmetics only with cosmetic functions (Art. 20 Reg. 1223/2009); HWG

Checklist before every publication

Not a word about detecting, preventing, treating or curing diseases – not in images, shelf labels or social media replies either.
For food supplements, only authorized claims, with conditions of use and mandatory information met.
No references to recommendations of individual doctors or health professionals in product advertising.
Gene-based recommendations are labeled as logical conclusions, with the standard note included.
Cosmetics are described with cosmetic functions.
In Switzerland: claims under Annex 14 LIV, mandatory information under Art. 14(3) GUMG.
A second person has proofread – if in doubt, an expert body.

Frequently asked questions

May my pharmacy personally recommend a food supplement?

Counseling is of course allowed. In advertising for a food, however, health claims that make reference to recommendations of individual doctors or health professionals are not allowed (Art. 12(c) Regulation (EC) No 1924/2006). Have a poster saying “Recommended by our pharmacist” next to a health claim checked legally beforehand.

Does Germany’s HWG apply to lifestyle genetic analyses?

The HWG applies to medical devices, including in vitro diagnostics, and to other procedures and treatments insofar as the advertising statement refers to recognizing, eliminating or alleviating diseases, suffering, bodily harm or pathological complaints (Section 1(1) Nos. 1a and 2 HWG). If you advertise a lifestyle analysis without any disease reference, No. 2 does not apply. The ban on misleading advertising under the UWG always applies.

May I adapt the wording of a health claim?

Only in a way that keeps the same meaning for consumers. “Contributes to the normal function of the immune system” does not become “boosts your defenses.” Also check the condition of use: many claims require the product to be at least a source of the nutrient.

Which advertising rules apply in Switzerland?

For food supplements, health claims are only allowed if they are provided for in Annex 14 LIV or authorized by the FSVO (Art. 31 LIV); foods must not be given the appearance of a therapeutic product (Art. 12(2)(d) LGV). Advertising for genetic tests outside medicine must inform about the rules on initiation, information and communication of results (Art. 14(3) GUMG, Art. 4(2) GUMV).

May I advertise “tested quality to EU standards”?

Be careful: food information must not suggest that a food has special characteristics when all similar foods have them (Art. 7(1)(c) Regulation (EU) No 1169/2011). For cosmetics, claims that present mere compliance with minimum legal requirements as a specific benefit are not allowed (Regulation (EU) No 655/2013, Annex, criterion 1). Name concrete, verifiable facts instead.

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Note: This guide is general information for businesses and professionals and does not replace medical or legal advice. The genetic traits determined in a genetic analysis are well documented (each gene included is backed by at least three independent studies); recommendations derived from them are logical conclusions, not scientifically proven. Regulations can change; errors and changes excepted.