Kunsei Club Submits Administrative Review Request Against Consumer Affairs Agency's Non-Disclosure Decision (No. 319 Food Labeling Division)

Kunsei Club Co., Ltd. (President and Pharmacist, Masaaki Mori) submitted an administrative review request on June 15, 2026, seeking the cancellation of the Consumer Affairs Agency's Food Labeling Division's decision not to disclose administrative documents (Document No. 319 Food Labeling). This request follows a prior telephone inquiry on June 2, 2026, during which the division refused to identify the source documents that served as the basis for using the term 'puberulic acid,' instead advising that any objections should be pursued through formal administrative review.

Content of the Non-Disclosure Decision (Background)

The Food Labeling Division issued its non-disclosure decision (No. 319 Food Labeling) on April 20, 2026. The stated reason for non-disclosure was: 'All instances where the term 'puberulic acid' was used in public communications (such as warnings and Q&As) were either materials distributed by the Ministry of Health, Labour and Welfare or direct quotations from those materials. The Agency has neither created nor obtained any administrative documents concerning the decision-making process behind the use of this term, and therefore does not possess such documents.'

Details of the Telephone Inquiry

Prior to filing the review request, on June 2, 2026, the company contacted the responsible officer at the Food Labeling Division by phone to request clarification on the specific source documents cited in the non-disclosure decision. The officer responded that they could not answer questions regarding the content of the disclosed documents and advised that any dissatisfaction should be addressed through an administrative review under the Administrative Appeal Act. No specific explanation was provided regarding the nature of the documents cited as sources.

Filing of the Administrative Review Request

In response, on June 15, 2026, the company submitted a formal request for administrative review to the Director-General of the Consumer Affairs Agency, seeking the cancellation of the decision. Since the non-disclosure rationale continues to assert that materials were 'distributed or quoted from the Ministry of Health, Labour and Welfare' without identifying the actual source documents, the company believes this decision fails to meet the application criteria under Article 9, Paragraph 2 of the Act on Access to Information Held by Administrative Organs.

The Company's Position

The company maintains that, as long as the agency continues to refuse to respond to inquiries about the content of administrative documents, the justification for non-disclosure remains inadequately explained. The company will continue to verify and document the facts, including the progress of the administrative review, and will disclose additional information as necessary.

[Company Overview]

Company Name: Kunsei Club Co., Ltd.

Headquarters: Hayashima-cho, Tsukubo-gun, Okayama Prefecture

Business Activities: Food manufacturing and sales

Red Yeast Rice Information: https://kunsei.com/archives/category/benikoji