What is the goal of the administrative review request?

To verify the consistency of MHLW's claim that it did not announce 'puberulic acid' and to demand document disclosure.

Why is 'puberulic acid' an issue?

It was widely reported as the cause, but MHLW denies announcing it, causing public confusion and business impact.

What should consumers know about this case?

There are inconsistencies in government communications, suggesting the cause may not be confirmed; source verification is key.

Three Administrative Review Requests Submitted En Masse to the Ministry of Health, Labour and Welfare (16th, 17th, and 18th Overall) Targeting the April 22 Non-Disclosure Decision Stating 'There Is No Fact of Publicizing Puberulic Acid'

Published Jul 5, 2026 7:00 PM ・ Updated Jul 8, 2026 6:12 PM ・ 9 min read ・ Source: PR TIMES

On April 22, 2026, the Ministry of Health, Labour and Welfare decided not to disclose documents (non-existence), claiming 'there is no fact of designating or publicizing puberulic acid as the causative substance.' In response, our company has collectively submitted three administrative review requests to challenge the validity of this decision.

Overview

Kunsei Club Co., Ltd. (Hayashima-cho, Okayama Prefecture, Representative Director and Pharmacist Masaki Mori) has collectively submitted three administrative review requests (16th, 17th, and 18th overall) to the Minister of Health, Labour and Welfare. All requests target the Ministry's administrative document non-disclosure decision dated April 22, 2026 (MHLW No. 0422-2), seeking re-examination of the Ministry's judgment that documents regarding the decision-making process of designating 'puberulic acid' as the causative substance 'do not exist.'

Content of the Targeted Non-Disclosure Decision

Our company requested disclosure of administrative documents related to the decision-making process in the fiscal year 2024 red koji-related incident, including the rationale for using the term 'puberulic acid,' scientific evaluation processes, meeting records with Osaka City Public Health Center and the National Institute of Health Sciences, and materials from expert panel meetings. In response, the Ministry of Health, Labour and Welfare issued a decision (MHLW No. 0422-2) on April 22, 2026, stating that 'there is no fact of designating or publicizing puberulic acid as the causative substance,' and therefore the documents were neither created nor obtained, resulting in non-disclosure (non-existence).

Our Company's Position

In 2024, 'puberulic acid' was widely reported as a potential causative substance for health damages. However, the current decision asserts that there was 'no fact of designation or public announcement,' claiming that no documents related to such a decision-making process exist. Given that the term 'puberulic acid' has indeed been used in administrative communications, our company requests a review of the reasonableness of the judgment that no documents exist regarding the use or consideration of this term.

Related Facts Confirmed (Discrepancies Between Government Agencies)

- The Consumer Affairs Agency's non-disclosure decision notice (No. 187 Shokuhin-ki, No. 319 Shokuhin-hyo dated April 20, and No. 184 Anzen dated April 21, all in Reiwa 8) explicitly states that all instances where the term 'puberulic acid' was used in the Agency's communications were 'either materials distributed from documents submitted by the Ministry of Health, Labour and Welfare or quotations from materials distributed by the Ministry.'

- In contrast, the Ministry of Health, Labour and Welfare's current decision denies any fact of 'designating or publicizing puberulic acid' as the causative substance. These explanations are inconsistent, and our company jointly requests clarification of this discrepancy.

Purpose of the Administrative Review Requests

Our company seeks to re-examine, through administrative review requests, whether sufficient efforts were made to search for and identify the target documents, and whether the rationale for 'non-existence' is reasonable in light of discrepancies among official documents. This case represents our position as a business operator that has traditionally handled red koji as a food product, demanding administrative accountability regarding the basis for determining the causative substance.

About This Series

This press release is part of an ongoing series issued since March 10, 2026. All previous releases are available at https://kunsei.com/archives/category/benikoji.

Company Overview

Company Name: Kunsei Club Co., Ltd.

Representative: Representative Director and Pharmacist Masaki Mori

Address: 611-1 Maekata, Hayashima-cho, Kita-kume District, Okayama 701-0303

Business: Manufacturing and sales of ham and sausages

Contact: [email protected]

Red Koji Related Site: https://kunsei.com/archives/category/benikoji

FACT BOX

Source: PR TIMES
Category: News

Three Administrative Review Requests Submitted En Masse to the Ministry of Health, Labour and Welfare (16th, 17th, and 18th Overall) Targeting the April 22 Non-Disclosure Decision Stating 'There Is No Fact of Publicizing Puberulic Acid'

⚡ Key Points