This guide describes the rules in Spain. If you run a pharmacy elsewhere, the principles carry over but the legal references do not.
What retail media is, and is not, in a pharmacy
The term comes from online retail: a large retailer sells brands ads inside its own website and ties them to its purchase data. In a physical store it means the same thing on a different medium. IAB Europe and IAB, in their December 2024 standards, define in-store retail media as advertising inventory that uses retail data to plan, run and measure activity inside the store, made available to brands. They focus on screens, audio and connected formats.
Applied to a pharmacy, the definition loses some of its grandeur. There is a space customers walk through, a manufacturer who wants them to look at its product, and an owner who decides on what terms. What is absent, or far scarcer than in a supermarket, is individual purchase data: a small pharmacy does not have a loyalty scheme with millions of receipts. Its strength is different: counter trust and proximity to the product.
It helps to keep this apart from things that look similar:
- Manufacturer promotions built into the price. When a manufacturer funds a parapharmacy offer, that is a trade term, not advertising. It shows up on the shelf label (see the guide to electronic shelf labels in pharmacies) and needs no screen.
- Your own signage content. Health tips, opening hours, services. That is the subject of the digital signage guide. It can be combined with brand campaigns, but it is not the same thing.
- The general definition of the concept. For retail media in any shop, with its generic formats and metrics, this guide is not the place. It covers only what changes when the shop is a pharmacy.
FarmaConnect's physical medium for this is the LCD rail, a long, thin screen along the shelf edge. This guide does not explain the product; it explains the business you can build with it, or with any similar medium.
Why manufacturers pay for shelf space
A manufacturer selling through pharmacies competes for a decision made in a few seconds. For indication-based medicines, that decision runs through the pharmacist's advice. For dermocosmetics, hygiene or supplements, it also runs through what the customer sees while walking round the store. That is where a brand video above its own product makes sense for a manufacturer, which is why brands have long bought gondola ends, display units and posters.
A screen adds three things to that menu: movement, flexibility (the autumn campaign changes without printing anything) and the ability to say what actually ran. What it does not add, and it is worth saying, is a guarantee of sales. A space is worth what its audience is worth, and a pharmacy with forty customers a day does not hold the same inventory as one with four hundred.
The wider market has grown enough that IAB Spain published an update to its Retail Media White Paper in November 2025. There are, however, no reliable public figures for this business inside Spanish pharmacies that we can cite, so this guide includes none.
What you can advertise and what you cannot
This is the non-negotiable part. The manufacturer pays, but responsibility for what is shown in your store is shared, and the advertising rules do not depend on who funds the ad.
Medicines. The Consolidated Medicines Act (article 80.1) only allows advertising to the public of medicines that are not funded by the public health system, can be used without medical diagnosis or follow-up, and are not psychotropic or narcotic. Royal Decree 1416/1994 (article 7) expressly excludes prescription medicines and those within the National Health System pharmaceutical benefit. A screen carrying the brand of a prescription medicine is simply prohibited advertising, whoever the customer is.
Where a medicine can be advertised, the message must make clear that it is an advertisement for a medicine, include its name and correct-use information, and invite people to read the leaflet and ask the pharmacist (article 80.2 of the Act and article 5 of the Royal Decree). It may not promise a cure or use testimonials. Article 6 of the Royal Decree lists banned content, including suggesting that seeing a doctor is unnecessary, and prohibits mentioning certain conditions, such as diabetes, cancer or sexually transmitted diseases, in advertising aimed at the public.
One point to check with your professional association: Royal Decree 1416/1994 (article 22) requires prior approval from the health authority for advertising to the public, whereas the 2015 Act (article 80.3) states that advertising of non-prescription medicines does not need prior administrative authorisation, although the authorities may monitor it. Both texts coexist in practice, and the autonomous regions apply their own criteria. Which procedure applies in your region is a question for your association, not for this guide.
Parapharmacy, cosmetics and supplements. Here the usual obstacle is Royal Decree 1907/1996, which generally prohibits advertising of products with a claimed health purpose except in the cases the text itself provides for. In practice the risk lies in health claims ("reduces", "prevents", "cures") more than in the product. The manufacturer usually brings a spot that has already been vetted, but the space is yours and the message is seen in your store. Asking for the material in advance and reserving the right to reject it is part of the contract, not a sign of distrust.
Material aimed at professionals. Royal Decree 1416/1994 reserves technical-scientific information for prescribers and dispensers (articles 10 to 15). If a manufacturer wants to show something meant for the pharmacist, it cannot be placed where the general public can see it. A customer-facing counter screen and a back-office screen are different media for the purposes of the rules.
The guide to price and advertising regulation expands on this framework, and the article on how to advertise a medicine without breaking the rules goes down to the level of specific messages.
Pricing models
There are three ways to put a price on a space. None is better in the abstract; each fits a different view of the relationship with the manufacturer.
| Model | How it is calculated | Advantage for the pharmacy | Risk |
|---|---|---|---|
| Flat fee | One amount per screen, period or campaign (month, quarter, campaign fortnight) | Easy to budget and invoice. | If the space performs below what was promised, the manufacturer does not return. |
| Cost per thousand impressions (CPM) | A price is set per thousand plays or thousand opportunities to see | The price grows with real audience. | You must count properly: what is an impression in a pharmacy? |
| Cooperative (co-op) or trade terms | Visibility is paid for with discounts, joint campaigns, rebates or other advantages | No need to be paid in cash, and it aligns the manufacturer with your business. | The closest to the legal danger zone (see below). |
Flat fee. This is the most honest starting point for a pharmacy with no audience history. You define which screens, how many hours a day, what share of the loop and for how long, and set an amount. The catch is to keep the loop short: if the manufacturer shares a screen with five others, next quarter's buyer will want to know how much of its time actually ran.
CPM. Cost per thousand impressions comes from digital advertising and works if there is a shared definition of an impression. The IAB standard distinguishes opportunity to see (being in the screen's exposure zone) from viewable impression (where conditions on size, dwell time and distance are also met), and recommends not treating every presence as a view. In a pharmacy a few metres wide, the exposure zone is almost the whole store, which simplifies the calculation but does not make it automatic: without a counter or a defensible estimate, CPM becomes an invented number.
Cooperative. "Co-op" actually covers deals of very different natures. A manufacturer that provides the hardware, or pays half of the screen that shows its products, is not in the same territory as one that offers a better margin in exchange for visibility. The latter needs care, which is the reason for the next section.
A practical rule: if you have no audience measurement of your own, start with a flat fee and collect data for a quarter. With that in hand, the conversation about CPM will be less theoretical.
Where it collides with the law and with independence
Two separate questions, best not mixed: what the law says, and what professional common sense says.
Incentives to the dispenser
Article 4.6 of the Consolidated Act prohibits offering, directly or indirectly, any kind of incentive, bonus, discount, premium or gift to professionals who prescribe, dispense or administer medicines, by anyone with an interest in their production or sale. It provides limited exceptions: prompt-payment or volume discounts from wholesalers to pharmacies, provided they do not favour one product over its competitors and appear on the invoice, and discounts on publicly funded medicines that are registered monthly with the Ministry of Health. Royal Decree 1416/1994 says something similar in article 17, with an exception for objects of insignificant value and no relevance to pharmacy practice.
Is a payment for advertising a prohibited incentive? There is no single answer, and this guide is not legal advice. What can be said is where the higher-risk and lower-risk lines lie:
- Lower risk. A genuine advertising service (screen, time slot, duration), at a price that resembles the market, with a written contract, an invoice and proof that it ran. The payment does not depend on how many units you buy or dispense.
- Higher risk. Visibility exchanged for better purchase terms, rebates or gifts, especially if the result favours one medicine over others, or if payment is linked to recommending. There the boundary between advertising and a reward for dispensing blurs.
A practical consequence is to separate the two worlds on paper. The commercial purchase condition goes in one document and through one channel; the advertising service goes in another. And if a manufacturer's offer mixes the two, that is the moment to ask your association before signing. Visibility deals traded for better terms or rebates, common in the trade and mentioned on FarmaConnect's own website too, sit squarely in the higher-risk zone.
Professional independence
Article 4.2 of the Consolidated Act bars community pharmacists from holding direct financial interests in manufacturers, intermediaries or wholesalers. Being paid for a screen is not being a partner in a manufacturer, and there is no basis to call it incompatible. But it signals the law's intent: that a pharmacist's recommendation should not answer to a financial interest.
The real risk is more mundane. If customers start to feel that the pharmacy recommends what it advertises, the screen costs the pharmacy more than it earns. Some rules that well-run pharmacies tend to adopt:
- A written policy. Which categories you accept and which you refuse, which messages you reject, and who decides.
- Limited exclusivity. A manufacturer does not buy your whole shelf in its category, nor the right to keep competitors out of your spoken recommendations.
- Visible advertising marker. What is an ad is presented as an ad, distinct from the pharmacy's own health advice.
- Right of veto. The owner can pull content without penalty if they believe it breaks the rules or does not fit their judgment.
What the contract should say
An advertising-space contract in a pharmacy does not need a hundred pages, but it should cover points that are forgotten until there is a problem.
- Exactly what is being bought. Screens, location, term of the agreement, time slot, length of the ad, and number of plays or share of the loop.
- What content runs. Video reference, delivery date and expiry date. If the spot changes, it is approved again.
- Who answers for the content. The manufacturer warrants that its advertising complies with the rules (including any authorisations that apply) and that claims are substantiated. The pharmacy may remove anything it considers non-compliant.
- Price and payment. Amount, frequency, invoice. Not conditional on purchases or dispensing.
- Reporting. What is delivered, by when, and in what detail (see the next section).
- Exclusivity and competitors. Which categories may not be sold to a direct competitor and for how long, and what happens if a mandatory public-health campaign comes up.
- Termination. Grounds for ending the deal, notice, and what happens to paid plays that did not run because of a fault.
- Data. If audience measurement uses sensors or cameras, who is the data controller and what data the manufacturer receives (ideally aggregates only).
A lawyer's review of a template contract costs little compared with renegotiating one signed lightly. And if the pharmacy belongs to a cooperative, buying group or franchise, a template or shared policy may already exist.
What to report and how to measure it
A manufacturer that pays wants to know that what it paid for happened. There are three levels of reporting, from least to most effort.
- Proof of play. What content ran, on which screens, on which dates and how many times. The screen-management platform should provide this, and it is the reasonable minimum. Without it, collecting a flat fee is hard to defend.
- Estimated audience. How many people were in a position to see it. The IAB standards speak of opportunity to see and viewable impression adjusted for dwell time and exposure zone. In a pharmacy, a simple estimate (receipts per day, or checkout traffic, by time slot) is more defensible than a precise figure with no method.
- Sales effect. The measurement the manufacturer cares most about, and the hardest. The IAB standard proposes comparing test and control stores, matched on prior sales, size and format. With a single pharmacy there is no control group; with a network of branches there is. For an independent owner, the realistic option is to compare your own category before and during the campaign, and to say plainly that it does not prove causation.
On measuring people with sensors or cameras: if the technology processes personal data (even just to count), the GDPR applies. That means a lawful basis, information for the customer, and minimisation. Counting without identifying is the simplest; anything that recognises faces belongs to a different risk category. Before installing anything, consult a data protection officer.
How to start without overcomplicating it
A reasonable order for a pharmacy starting from zero:
- Define your policy on what you accept (see above), in writing.
- Work out your audience simply: customers per day, busiest time slots, average time in the store.
- Choose one or two manufacturers you already work with and whose category complements your range, not the ones that bid the most.
- Propose a flat fee for one quarter, with a contract and proof of play.
- Review the results and adjust before extending to other screens or to an impressions-based model.
All of this works the same whether the medium is a rail, a counter screen or a window display. What the technology does need is the ability to schedule campaigns by time slot and to produce the proof. Before promising a report to a manufacturer, ask your supplier, FarmaConnect or anyone else, for a real sample of the proof-of-play report its platform produces.
Common mistakes
- Accepting a spot without watching it. The manufacturer brings material that is fine for television, which need not be fine for your store.
- Mixing the commercial offer and the space. This is the shortcut to the article 4.6 problem.
- Charging by CPM without a counter. A price per impression that nobody can verify.
- Overloaded screens. If the loop has seven ads from six brands, customers stop looking and manufacturers stop paying.
- Confusing advertising with advice. Putting the pharmacist's advice and the brand that pays for it in the same frame damages both.
Summary
Selling space to manufacturers can be a reasonable income source for a pharmacy, as long as it is treated as an advertising service with a price, a contract and proof, not as a reward for recommending. What can be shown is limited by the rules on advertising medicines and products with a health purpose. Independence is protected with written rules before the first campaign. And performance is measured honestly, accepting that a small pharmacy cannot promise what a hypermarket promises.
To return to the whole set, the guides page lays out the full route.
Sources
- Real Decreto 1416/1994, de 25 de junio, por el que se regula la publicidad de los medicamentos de uso humano (BOE) [Royal Decree on advertising of medicines for human use]
- Real Decreto Legislativo 1/2015, texto refundido de la Ley de garantías y uso racional de los medicamentos y productos sanitarios (BOE) [Consolidated Medicines Act]
- Real Decreto 1907/1996, de 2 de agosto, sobre publicidad y promoción comercial de productos, actividades o servicios con pretendida finalidad sanitaria (BOE) [Royal Decree on products with claimed health purpose]
- IAB Europe and IAB: In-Store Retail Media Definitions and Measurement Standards (December 2024)
- IAB Spain presenta un nuevo Libro Blanco de Retail Media (Puro Marketing, November 2025)
- Regulation (EU) 2016/679 (GDPR), EUR-Lex
