Counterfeit Advantage and Frontline: Issues and Risks
by Stacy Pober (17 March 2004)
The Environmental Protection Agency (EPA), Bayer Animal Health, and Merial recently issued press releases about a recent investigation that found that "counterfeit" versions of Bayer Advantage and Merial's Frontline were being sold to consumers. This issue recently came up on VETMED, an email discussion list that I moderate.
Because there seemed to be a lot of speculation among pet owners about this issue, I decided to look into the matter a little more thoroughly.
The EPA documents and company press releases, [see references at end] have been very vague regarding any specific problems that have come up with the counterfeit versions of these products. For example, they do not mention whether any pet has been harmed by a counterfeit version of either of these products.
One of the problems here is the many meanings that the EPA and manufacturers have given to the word "counterfeit". Most of us think of a counterfeit as something that is a bogus, imiation version of something. And indeed, a counterfeit drug may be one that is completely different than the genuine article. However, the EPA and the companies that make Advantage and Frontline also consider a product counterfeit if it is the exact same chemical as the genuine one, but if it was was manufactured, labelled and originally sold by the manufacturer for use in another country. For example, Bayer Advantage is made and sold in France. However, if a U.S. retailer imports the French product, relabels it in English and sells it to U.S. consumers, the company and the EPA consider that to be a counterfeit.
The recent joint EPA/Merial/Bayer investigation was focussed on the retail sale of these pesticides. In some cases, the retaillers had relabelled the products to indicate U.S. origin, and then resold them to consumers in pet stores.
But there has been another source for 'gray market' versions of Frontline and Advantage. Some American consumers have found it cheaper to purchase these from foreign internet or mail-order vendors than from their veterinarians. These products are not purchased for resale, and according to the purchasers who have posted to some of the email lists, the imported products are shipped to them with the original Australian labelling.
My specific questions about this were whether there have been any pets harmed by counterfeit Advantage or Frontline. I also wanted to know if there were cases where a different pesticide was used in a counterfeit version, or where the correct chemical was used but the dosages were significantly higher or lower than the label indicated.
I did a little research and contacted Bayer, Merial, and the EPA on 3/15/2004.
From the reading I did and calls I made, here's my conclusions:
Retailers buying Frontline or Advantage from foreign sources and relabelling them to indicate U.S. origin are breaking the law. There's good reason to question whether such retailers are trustworthy sources for these products.
Any store relabelling products to indicate EPA approval for illegally imported stock is, to put it mildly, ethically challenged. These retailers are putting false EPA approval statements on the labels. If they are doing this, they might be putting other misstatements on the labels, such as incorrect dosage information.
I was unable to independently verify the Merial rep's citation of "wrong dosage" imported Frontline. Still, I personally would not buy product that has been relabelled. As a consumer, I have a basic expectation that the company selling me a product has put a label on it that is factually correct. I don't want to deal with someone who's cutting this particular corner.
However, the question of consumers who are directly purchasing their Frontline or Advantage overseas is a separate issue. This is probably a very low risk choice. Most likely, you will get the product you expect. As with any purchase, it's best to try to deal with reputable firms. Sometimes, the least expensive source is not the most reliable one.
Any pesticide sent to the U.S. is supposed to come under the regulatory oversight of the Environmental Protection Agency even if it bears the original label from its country of origin. Thus, it may be technically illegal for consumers to purchase Frontline or Advantage from overseas sources without obtaining an EPA permit. Still, the Advantage or Frontline sold in Australia is basically the same product as the Advantage and Frontline sold in the U.S.A.. Even the manufacturer's reps admit this, though they referred to such illicitly imported products as "counterfeits".
As one VETMED subscriber pointed out, the major drawback of using directly imported versions of these products is that the manufacturers will disclaim all responsibility if a problem arises. However, a few years back, I purchased a bad batch of Advantage through my veterinarian. It didn't harm the dogs - or the fleas, for that matter. It didn't do anything at all. Bayer would not make good on their guarantee in that case, even though I had purchased it from my vet. So, it's not been my experience that the manufacturers will stand by their product even when the consumer follows their rules. (I still would use Advantage if the need arose - subsequent purchases did work as expected.)
I can't definitively say that no counterfeit versions of these products have harmed pets. However, I feel relatively confident that if this had happened, the EPA and the manufacturers would be happily sharing that information with the public. If I hear of any significant information about this, I will post it to VETMED.
EPA FACT SHEET - Retailers and Counterfeit Pet Products
EPA: Counterfeit Pesticide Products for Dogs and Cats. Information for Consumers
EPA: Counterfeit Pesticide Products For Dogs and Cats Found - Retailers Ordered to Stop Sales
Merial Assisting with US EPA Actions Announced Against Counterfeit FRONTLINE Packaging
Bayer Animal Health Continues the Fight to Stop Unauthorized Sale of AdvantageŽ
Copyright 2003, S. Pober, Golightly Greyhounds, roo (at) raingoddess.com
This article was originally posted to the VETMED list.
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