[Regular Survey] Examples of Advertisements Potentially Violating the Pharmaceutical and Medical Device Act and the Premiums and Representations Act, July 3, 2026

REGAL CORE Inc. (Shibuya-ku, Tokyo, President and CEO: Hayato Tanoue), which handles pharmaceutical and medical device act checks, regularly conducts surveys on the advertising status of article LPs (landing pages) [1] that may contain expressions violating laws such as the Pharmaceutical and Medical Device Act and the Premiums and Representations Act. We report the results.

Survey Results

Following the previous survey, the article LPs investigated this time also showed the distribution of content that is highly likely to be problematic under the Pharmaceutical and Medical Device Act and the Premiums and Representations Act. Details are summarized below with specific examples.

Survey Method

Survey Period: May 2026 - July 2026

Survey Target: Each time, multiple web media are arbitrarily selected, and article LPs of advertisements distributed primarily through recommendation widgets posted on those web media.

Survey Method: Every half month, we identify article LPs of advertised products posted on multiple web media, and examine and evaluate their appeal expressions from the perspective of protecting users based on the Pharmaceutical and Medical Device Act and the Premiums and Representations Act to see if there are any problematic expressions.

Details of Findings

We summarize some of the appeal expressions contained in the article LPs obtained during the survey period that are considered to be in violation of laws and regulations. [2]

In addition, the following appeal expressions have been confirmed frequently, including those pointed out in the past.

For products falling under health foods, expressions that violate claims of medicinal efficacy and effects (Pharmaceutical and Medical Device Act), exaggerated claims (Health Promotion Act), or misrepresentation of superiority (Premiums and Representations Act)

a. Expressions claiming effects on specific body parts or bodily functions that cannot be claimed.

Example 1: Expressions such as "utilizing the function of female hormones," "adds firmness to the bust," "plump breasts," "anyone can achieve plump, beautiful breasts," "female hormone support."

Example 2: (Referring to hair) "shiny and smooth."

Example 3: (Referring to skin) "plump," "detoxifying effect," "prevents body oxidation," "rejuvenation," "youthful appearance," and expressions that mislead users into believing there are effects on the skin, such as blemishes, using BA images.

Example 4: "Eliminates bad breath from the stomach and intestines," "eradicate bad bacteria that cause bad breath completely," "eliminates existing bad bacteria (= tongue coating)."

b. Expressions claiming weight loss simply by taking the product, or excessively claiming weight loss.

Examples: "Guaranteed to lose weight," "promotes the excretion of fatty stools," "boosts metabolism," "burns fat," "achieve a lean physique," "13.1kg weight loss in 2 weeks," and expressions that suggest excessive weight loss in combination with BA images.

c. Expressions that suggest male function improvement simply by taking the product.

Examples: "Male hormone in a bottle," "sex drive boost," "testosterone boost," "graduation from menopause."

For products falling under Foods with Function Claims, expressions that violate exaggerated claims (Health Promotion Act) or misrepresentation of superiority (Premiums and Representations Act)

a. Expressions that clearly deviate from the scope of functions that the product can claim, based on its notification and mechanism of action.

Examples: For functions related to improving contrast sensitivity in vision, expressions that suggest glasses will no longer be necessary; expressions that mislead users into believing vision will improve using BA images or comparative images; functions related to fatty stool excretion and metabolism enhancement; expressions that mislead users into believing their constitution has improved and they will not regain weight; expressions that mislead users about the extent to which walking ability can be maintained or improved, such as "can walk forever" and BA images showing smooth walking without a cane.

Expressions that claim exaggerated effects at a scientifically unimaginable level, such as "10kg of impacted stool accumulated in the intestines can be excreted."

b. Expressions that claim effects from ingredients other than the functional ingredient, or that the product itself has a function.

Example: Expressions suggesting that XX (an ingredient other than the functional ingredient) excretes lipids and improves intestinal environment.

c. Expressions that suggest weight loss without moderate dietary restrictions or exercise, or expressions that suggest excessive weight loss beyond the scope of the Consumer Affairs Agency's guidelines.

Examples: Expressions such as "lose weight without any muscle training or dietary restrictions," "lose over 10kg in one month," "fat drastically reduced in two weeks."

For products falling under cosmetics (including quasi-drugs), expressions that violate the Fair Advertising Standards for Pharmaceuticals and Medical Devices, etc.

a. Expressions claiming efficacy and effects that deviate from the table of efficacy and effect ranges.

Example 1: For depilatory agents, expressions that can be interpreted as hair growth inhibition effects, such as "permanent hair removal level," "promotes skin regeneration," "hair growth becomes less frequent," "hair becomes thinner."

Example 2: For soaps (face washes, cleansers, body soaps, etc.), expressions such as "excretes toxins," "skin quality itself changes," "prevents inflammation," and "fights bad bacteria" (despite not having approval as a quasi-drug for sterilization).

Example 3: For bust creams, expressions such as "rapid growth from A to F," "can achieve G cup in 2 weeks," "anyone can increase bust size," and expressions using BA images to suggest that breasts will enlarge simply by applying the product.

Example 4: For products related to blemishes, expressions such as "blemishes have disappeared," "blemishes have vanished," "as if blemishes never existed," "blemish detergent/bleach," and expressions that suggest blemishes will be cleared up in combination with images.

Example 5: For products related to wrinkles that are not quasi-drugs, expressions such as "wrinkles have completely disappeared," "wrinkles are taut!" suggesting that wrinkles will disappear.

Example 6: For hair growth tonics, expressions such as "applied hair transplant," "can grow hair without anyone noticing," and expressions using BA images to suggest that hair will grow. Also, expressions suggesting effects on gray hair, such as "gray hair will stop growing," "gray hair care."

Example 7: For products that fall under eyelash serums that are not quasi-drugs, expressions suggesting eyelash growth or hair growth effects, such as "eyelash cultivation," "eyelashes have grown," "hair growth tonic," "grow eyelashes."

Example 8: For toothpastes, expressions that suggest teeth will become whiter without stating it is a brushing effect (mouthwash products). Also, expressions suggesting antibacterial effects due to ingredients rather than physical effects. Additionally, exaggerated claims such as "gums that were so loose they were wobbly have become strong enough to bite hard objects."

Example 9: For products that fall under shampoos and conditioners, expressions that suggest hair quality improvement or hair growth effects, such as "changes in hair quality," "cultivation of black hair."

Example 10: For cosmetics such as perfumes, expressions that suggest the fragrance acts on the brain or mind, such as "aphrodisiac" or "excites women."

Example 11: For products that fall under cosmetics (including quasi-drugs), expressions that suggest other effects that cannot be claimed. Expressions such as "eliminates sagging skin," "cares for pores," "rejuvenates cells," "has anti-aging effects," "promotes turnover," "excretes melanin," "produces collagen."

For products falling under pharmaceuticals, expressions that violate the Fair Advertising Standards for Pharmaceuticals and Medical Devices, etc.

a. Expressions that suggest a curative effect, similar to that of a drug intended for treatment, even though it is a drug intended for symptomatic relief.

Example 1: Expressions such as "nerve treatment drug," "specific treatment drug," "intended for treatment."

Example 2: "Blemish eraser," "complete elimination of dark blemishes," and expressions using BA images to mislead users into believing there is an effect of completely eliminating blemishes.

b. Expressions that claim a mechanism of action that would not be permitted even for pharmaceuticals.

Example: Expressions that treat large amounts of impacted stool accumulated in the intestines as if it were fat, and suggest that it can be excreted to cause weight loss.

Expressions that violate the Pharmaceutical and Medical Device Act, the Premiums and Representations Act, etc., regardless of product classification.

a. Expressions that guarantee efficacy and effects.

i. Expressions that claim the completeness of efficacy and effects, such as "always ~," "anyone ~," "perfectly ~," "reduce to zero ~," "disappear ~."

ii. Appeal expressions that excessively mislead users about efficacy, effects, or safety, such as "approved," "authorized," "recognized by the country/Ministry of Health, Labour and Welfare."

(Note: Since Foods with Function Claims are only notified, expressions suggesting approval may also be false.)

Other expressions that violate laws other than the Pharmaceutical and Medical Device Act and the Premiums and Representations Act, or expressions that have been pointed out/warned by the Consumer Affairs Agency in the past.

a. Advertisements that infringe on publicity rights (advertisements where it is clearly evident that the names or images of celebrities are used without permission).

b. Advertisements that solicit LINE registration by claiming excessive slimming effects or bust enhancement effects, and stating that no additional costs are incurred (advertisements closely resembling those warned by the Consumer Affairs Agency).

Some businesses have already made corrections to the expressions pointed out this time. We will update the content as the situation changes in the future. We have been continuously conducting surveys since August 2022, improving our survey methods and interpretations as needed, and will continue to report the results.

[1] Article LP: An advertisement page in the style of an article posted on a web media.

[2] The content of the advertisement expression is considered problematic, not the product itself, and is listed as an example.