Periodic Survey: Examples of Advertisements with Expressions Potentially Violating the Pharmaceutical Affairs Law and the Act Against Unjustifiable Premiums and Misleading Representations

REGAL CORE Inc. (Shibuya-ku, Tokyo; CEO: Hayato Tano), a company specializing in Pharmaceutical Affairs Law compliance checks, regularly conducts surveys on the advertising distribution of article landing pages (LPs) [1] that contain expressions potentially violating laws such as the Pharmaceutical Affairs Law and the Act Against Unjustifiable Premiums and Misleading Representations (Jouhyou Hou). We hereby report the results of our latest survey.

Survey Results

Once again, this survey confirmed the distribution of article LPs containing expressions that may violate the Pharmaceutical Affairs Law or the Act Against Unjustifiable Premiums and Misleading Representations (Jouhyou Hou). Details are summarized below with specific examples.

Survey Methodology

Survey Period: May 2026 – July 2026

Survey Targets: Multiple web media sites were selected arbitrarily each time, focusing on article LPs for advertised products distributed via recommendation widgets on these sites.

Method: Every two weeks, article LPs for advertised products on multiple web media were reviewed. Their promotional expressions were evaluated from a consumer protection standpoint, based on the Pharmaceutical Affairs Law and the Act Against Unjustifiable Premiums and Misleading Representations, to identify potentially problematic claims.

Detailed Findings

Below are some of the promotional expressions identified during the survey period that may violate applicable laws. [2]

Additionally, the following types of expressions were frequently observed, including those previously highlighted:

For products classified as health foods, expressions violating pharmaceutical efficacy claims (Pharmaceutical Affairs Law), exaggerated advertising (Health Promotion Law), or misleading representations implying superior quality (Act Against Unjustifiable Premiums and Misleading Representations):

a. Claims asserting effects on body parts or functions that should not be advertised

Example 1: "Utilizes the function of female hormones," "adds firmness to the chest," "plump breasts for everyone," "anyone can achieve plump, beautiful breasts," "female hormone support"

Example 2: (pointing to hair) "shiny and silky"

Example 3: (pointing to skin) "plump," "detox effect," "prevents body oxidation," "rejuvenation," "looks younger," or using before-and-after (BA) images to mislead consumers into believing the product improves skin conditions such as spots

Example 4: "eliminates bad breath from the gastrointestinal tract," "completely eradicates odor-causing harmful bacteria," "eliminates existing harmful bacteria (i.e., tongue coating)"

b. Claims suggesting weight loss simply by consumption, or excessive weight loss

Example: "guaranteed weight loss," "expels fatty stools," "boosts metabolism," "burns fat," "achieves a slimming body type," "lose 13.1kg in 2 weeks," or using BA images to exaggerate slimming effects

c. Claims suggesting enhanced male function simply by consumption

Example: "drinkable male hormone," "explosive libido boost," "massive testosterone increase," "graduate from menopause"

For products classified as functional foods with registered claims, expressions violating exaggerated advertising (Health Promotion Law) or misleading representations implying superior quality (Act Against Unjustifiable Premiums and Misleading Representations):

a. Claims clearly exceeding the scope of functions permitted by the registered content and mechanism of action

Example: Suggesting that improved contrast sensitivity in the eyes could eliminate the need for glasses; using BA or comparative images to mislead consumers into believing vision has improved; claiming metabolic enhancement or fat expulsion functions; misleading claims suggesting permanent body constitution improvement with no rebound; exaggerated claims such as "able to walk forever" or BA images showing smooth walking without a cane, misleadingly suggesting maintained or improved walking ability

Claims asserting scientifically implausible effects, such as 10kg of accumulated feces in the intestines that can be expelled

b. Claims attributing functions to ingredients not designated as functional components, or claiming the product itself has functions

Example: Suggesting that ingredient "X" (not a functional component) expels lipids or improves intestinal environment

c. Claims of weight loss without diet or exercise, or excessive weight loss claims exceeding Consumer Affairs Agency guidelines

Example: "lose weight without any strength training or dieting," "lose over 10kg in one month," "dramatic fat reduction in two weeks"

For cosmetic products (including medicated cosmetics), expressions violating the Standards for Proper Advertising of Pharmaceuticals, etc.:

a. Claims of efficacy or performance beyond the approved scope

Example 1: Hair removal products claiming "permanent hair removal level," "promotes skin regeneration," "reduces hair regrowth," "thins hair," or similar expressions implying hair growth suppression

Example 2: Soap products (face wash, cleanser, body soap, etc.) claiming "expels toxins," "changes skin quality itself," "prevents inflammation," or "eliminates harmful bacteria" (despite lacking antibacterial approval as quasi-drugs)

Example 3: Breast creams claiming "rapid growth from A to F cup," "reach G cup in 2 weeks," "anyone can achieve breast enhancement," or using BA images to suggest breasts grow larger simply by application

Example 4: Products for spots claiming "spots disappeared," "spots eliminated," "spots as if never existed," "spot detergent/bleach," or using images to suggest spots become clean

Example 5: Non-quasi-drug anti-wrinkle products claiming "wrinkles completely gone," "wrinkles become taut!" or similar expressions suggesting wrinkles disappear

Example 6: Hair growth products claiming "paint-on hair transplantation," "grow hair without anyone noticing," or using BA images to suggest hair regrowth. Also, claims such as "prevents gray hair from growing," "gray hair care," suggesting effectiveness on gray hair

Example 7: Non-quasi-drug eyelash serums claiming "eyelash growth," "eyelashes grow longer," "hair growth agent," "grow eyelashes," or similar expressions suggesting eyelash growth or regrowth effects

Example 8: Toothpaste products suggesting teeth whitening without stating it's due to brushing (e.g., mouthwash). Also, suggesting antibacterial effects from ingredients rather than physical action. Additionally, exaggerated claims such as "gums so weak they wobbled now strong enough to chew hard foods"

Example 9: Shampoos and conditioners claiming "hair quality transformation," "growth of black hair," or similar expressions suggesting hair quality improvement or hair growth effects

Example 10: Perfumes and other cosmetics suggesting aphrodisiac effects or exciting women, implying the scent affects the brain or mind

Example 11: Cosmetics (including medicated cosmetics) claiming other unallowable effects, such as "eliminates skin sagging," "treats bumps," "rejuvenates including cells," "anti-aging effects," "promotes turnover," "expels melanin," "stimulates collagen production"

For pharmaceutical products, expressions violating the Standards for Proper Advertising of Pharmaceuticals, etc.:

a. Products intended for symptom relief claiming effects similar to curative medicines

Example 1: "nerve treatment medicine," "specialized treatment medicine," or expressions suggesting treatment purposes

Example 2: "spot removal," "complete elimination of even dark spots," or using BA images to mislead consumers into believing spots completely disappear

b. Claims asserting mechanisms of action not recognized even for pharmaceuticals

Example: Treating large amounts of accumulated feces in the intestines as if they were fat, and claiming weight loss by expelling them

Regardless of product classification, expressions violating the Pharmaceutical Affairs Law or the Act Against Unjustifiable Premiums and Misleading Representations:

a. Expressions implying guaranteed efficacy or effects

i. Claims such as "guaranteed to ~," "anyone can ~," "perfectly ~," "reduce ~ to zero," "~ will disappear," asserting complete efficacy