A case was confirmed where advertising expressions that our company pointed out as potentially violating the Pharmaceutical and Medical Device Act and the Premium Labeling Act in past regular surveys were cracked down by the Tokyo Metropolitan Government.
REGAL CORE, a company specializing in compliance checks for advertising laws, has confirmed a case where advertising claims they previously flagged as potentially violating the Pharmaceutical and Medical Device Act and Premium Labeling Act were indeed subject to enforcement action by the Tokyo Metropolitan Government. This incident involved a hair growth product, "IkuMo Nano Grow Rich," which was found to have made unsubstantiated claims about efficacy and used fabricated comparison images, leading to a Measures Order. REGAL CORE plans to expand its survey scope to include social media and international platforms.
📋 Article Processing Timeline
- 📰 Published: April 15, 2026 at 21:30
- 🔍 Collected: April 15, 2026 at 13:01
- 🤖 AI Analyzed: April 15, 2026 at 18:59 (5h 57m after Collected)
REGAL CORE Co., Ltd. (Headquarters: Shibuya-ku, Tokyo, President: Hayato Tanoue), which handles the Pharmaceutical and Medical Device Act checking business, conducts regular surveys on the advertising status of article LPs (landing pages) that contain expressions potentially violating laws such as the Pharmaceutical and Medical Device Act and the Premium Labeling Act. As of April 2026, the cumulative number of regular surveys has reached 34.
In past surveys, multiple businesses have received administrative dispositions such as business suspension orders based on the Act on Specified Commercial Transactions or measures orders based on the Premium Labeling Act. Recently, a crackdown on a hair growth product (quasi-drug) was announced. Upon comparing this with our company's past survey results, a connection with the crackdown content by public authorities was confirmed. Below, we report the details.
1. Crackdown Example
Measures Order based on the Premium Labeling Act
└ Case of Plucharm Co., Ltd. "IkuMo Nano Grow Rich"
On March 23, 2026, a Measures Order based on the Premium Labeling Act was issued by the Tokyo Metropolitan Government. The main violation details and the measures order are as follows:
1. Misleading Representation (Efficacy/Performance) regarding hair growth effect and comparison images
(1) Misleading Representation (Efficacy/Performance)
When selling to general consumers, on websites starting with the phrase "＼National approval for hair growth effect／" (hereinafter referred to as "Website 1") and websites starting with "85% OFF with survey response" (hereinafter referred to as "Website 2"), representations were made as if anyone could easily achieve hair growth effects to the extent that the thinning hair condition would visibly improve due to the action of the ingredients contained in the product. When requested to submit materials with reasonable grounds to support the representations, the company submitted materials, but they were not recognized as having reasonable grounds to support the representations.
(3) Misleading Representation (Comparison Images)
On Website 2, images showing the condition of hair before and after use were posted, making representations (Appendix 4) as if individuals who used the product easily achieved hair growth effects to the extent that the thinning hair condition visibly improved. In reality, the advertising production/operation company commissioned by the company created these by compositing images of people with thin hair onto model images they acquired, and they did not represent the actual effects of using the product.
2. Overview of Other Misleading Representations and Stealth Marketing (Summary)
* Regarding Other Misleading Representations:
Representations intended to mislead consumers were made, such as effects comparable to Nobel Prize-winning achievements, SNS posts fabricated by advertising companies, and false claims of being close to selling out. However, no supporting facts or grounds were recognized for any of these representations.
* Overview of Misleading Representations Corresponding to Stealth Marketing:
Advertisements were published throughout the article without the notation of "Advertisement" or "PR," and furthermore, company employees were presented as hair condition specialists without clearly stating that they were employees.
* ※ From the Tokyo Metropolitan Government HP (from press release by the Bureau of Social Welfare and Public Health on March 23, 2026)
https://www.metro.tokyo.lg.jp/information/press/2026/03/2026032307
2. Relation to Our Company's Surveys
Our company has repeatedly announced cautionary releases regarding "IkuMo Nano Grow Rich" and similar hair growth products, pointing out potential violations of the Premium Labeling Act and the Pharmaceutical and Medical Device Act.
The content of the Measures Order by the Tokyo Metropolitan Government has now been published, and it has been confirmed that expressions similar to those pointed out in our company's releases were mentioned in the said Measures Order. This is an example where the risks our company pointed out in the past have materialized, indicating that the said expressions have become targets of regulation by public authorities.
Our company will continue to conduct surveys and awareness activities to promote appropriate advertising expressions from the perspective of legal compliance.
【Periodic Survey】 Examples of Distribution of Advertising Expressions Potentially Violating the Pharmaceutical and Medical Device Act and Premium Labeling Act 2024.12.04
URL: https://regalcore.co.jp/news/periodic-report-2024.12.04
3. Future Policy
For over three years, we have conducted surveys on web media and have requested businesses to correct or stop advertising and delivery of expressions that may violate laws. Many businesses have cooperated, and expressions that may violate laws are gradually decreasing.
In recent years, compared to the past, consumers' eyes on web media advertisements are becoming stricter regarding their content. Furthermore, cases where stronger sanctions are imposed on exaggerated advertisements, such as business suspension orders under the Act on Specified Commercial Transactions, are increasing.
Our company will continue its regular surveys, further expanding its target businesses not only to web media but also to foreign mega-platformers that have not been targeted until now. On the other hand, advertisements with potentially illegal claims are scattered across media other than web media, such as SNS. Therefore, aiming for healthier advertising practices, we will endeavor to gradually expand our investigation scope to SNS, similar to web media.
In past surveys, multiple businesses have received administrative dispositions such as business suspension orders based on the Act on Specified Commercial Transactions or measures orders based on the Premium Labeling Act. Recently, a crackdown on a hair growth product (quasi-drug) was announced. Upon comparing this with our company's past survey results, a connection with the crackdown content by public authorities was confirmed. Below, we report the details.
1. Crackdown Example
Measures Order based on the Premium Labeling Act
└ Case of Plucharm Co., Ltd. "IkuMo Nano Grow Rich"
On March 23, 2026, a Measures Order based on the Premium Labeling Act was issued by the Tokyo Metropolitan Government. The main violation details and the measures order are as follows:
1. Misleading Representation (Efficacy/Performance) regarding hair growth effect and comparison images
(1) Misleading Representation (Efficacy/Performance)
When selling to general consumers, on websites starting with the phrase "＼National approval for hair growth effect／" (hereinafter referred to as "Website 1") and websites starting with "85% OFF with survey response" (hereinafter referred to as "Website 2"), representations were made as if anyone could easily achieve hair growth effects to the extent that the thinning hair condition would visibly improve due to the action of the ingredients contained in the product. When requested to submit materials with reasonable grounds to support the representations, the company submitted materials, but they were not recognized as having reasonable grounds to support the representations.
(3) Misleading Representation (Comparison Images)
On Website 2, images showing the condition of hair before and after use were posted, making representations (Appendix 4) as if individuals who used the product easily achieved hair growth effects to the extent that the thinning hair condition visibly improved. In reality, the advertising production/operation company commissioned by the company created these by compositing images of people with thin hair onto model images they acquired, and they did not represent the actual effects of using the product.
2. Overview of Other Misleading Representations and Stealth Marketing (Summary)
* Regarding Other Misleading Representations:
Representations intended to mislead consumers were made, such as effects comparable to Nobel Prize-winning achievements, SNS posts fabricated by advertising companies, and false claims of being close to selling out. However, no supporting facts or grounds were recognized for any of these representations.
* Overview of Misleading Representations Corresponding to Stealth Marketing:
Advertisements were published throughout the article without the notation of "Advertisement" or "PR," and furthermore, company employees were presented as hair condition specialists without clearly stating that they were employees.
* ※ From the Tokyo Metropolitan Government HP (from press release by the Bureau of Social Welfare and Public Health on March 23, 2026)
https://www.metro.tokyo.lg.jp/information/press/2026/03/2026032307
2. Relation to Our Company's Surveys
Our company has repeatedly announced cautionary releases regarding "IkuMo Nano Grow Rich" and similar hair growth products, pointing out potential violations of the Premium Labeling Act and the Pharmaceutical and Medical Device Act.
The content of the Measures Order by the Tokyo Metropolitan Government has now been published, and it has been confirmed that expressions similar to those pointed out in our company's releases were mentioned in the said Measures Order. This is an example where the risks our company pointed out in the past have materialized, indicating that the said expressions have become targets of regulation by public authorities.
Our company will continue to conduct surveys and awareness activities to promote appropriate advertising expressions from the perspective of legal compliance.
【Periodic Survey】 Examples of Distribution of Advertising Expressions Potentially Violating the Pharmaceutical and Medical Device Act and Premium Labeling Act 2024.12.04
URL: https://regalcore.co.jp/news/periodic-report-2024.12.04
3. Future Policy
For over three years, we have conducted surveys on web media and have requested businesses to correct or stop advertising and delivery of expressions that may violate laws. Many businesses have cooperated, and expressions that may violate laws are gradually decreasing.
In recent years, compared to the past, consumers' eyes on web media advertisements are becoming stricter regarding their content. Furthermore, cases where stronger sanctions are imposed on exaggerated advertisements, such as business suspension orders under the Act on Specified Commercial Transactions, are increasing.
Our company will continue its regular surveys, further expanding its target businesses not only to web media but also to foreign mega-platformers that have not been targeted until now. On the other hand, advertisements with potentially illegal claims are scattered across media other than web media, such as SNS. Therefore, aiming for healthier advertising practices, we will endeavor to gradually expand our investigation scope to SNS, similar to web media.