Japanese Advertising Compliance for Overseas Brands

The gap

An accurate translation can still be an illegal one.

Regulatory consultancies will get your product notified and your importer licensed. That work is real and I do not compete with it. But notification says nothing about your marketing copy, because the copy is written later, by a different team, in a different country.

The usual sequence: a brand completes its cosmetics notification or confirms its food is an ordinary food, launches in Japan, and hands its English marketing deck to a translator. The Japanese comes back faithful to the original. It is also, quite often, a violation of the PMD Act — and nothing in the notification process was ever going to catch it.

Japan regulates health claims through several statutes at once, and they do not map onto FDA, EFSA or MHRA categories. The most common failure is not a bad-faith claim. It is a claim that is completely normal in its home market and simply has no legal room to exist in Japanese.

Act on Pharmaceuticals and Medical Devices (PMD Act)

Act against Unjustifiable Premiums and Misleading Representations

Health Promotion Act

Act on Specified Commercial Transactions

Standards for Fair Advertising of Drugs

Foods with Function Claims (notified claims)

56 permitted cosmetic efficacy expressions

Five examples

Phrases that are unremarkable in English and unusable in Japanese.

These are not edge cases. They are the five I see most often in copy that has already been translated, approved internally, and published.

01 — "Clinically proven"

For a food, a clinical-efficacy claim is only available if the product is a notified Food with Function Claims, and then only within the exact wording of the notification. An ordinary food cannot borrow the credibility of a study, however real the study is. Citing your own trial does not create the entitlement.

02 — "Anti-aging"

Cosmetics in Japan may only claim from a closed list of 56 permitted efficacy expressions. Reversing or preventing ageing is not on it. "Age-defying care" — care appropriate to one's age — is the accepted formulation, and it carries a footnote requirement. The distinction looks cosmetic in English. It is the whole thing in Japanese.

03 — "Doctor recommended"

Endorsement by physicians, pharmacists and other healthcare professionals is prohibited in principle under the fair-advertising standards, on the reasoning that the public cannot evaluate the endorsement. This surprises overseas brands more than any other rule, because it is a selling point almost everywhere else.

04 — "#1 in the US"

A superiority claim needs a reasonable basis, and Japan's regulator has set four conditions: an appropriate comparison set, appropriate survey respondents, a fair method, and — the one that catches people — correspondence between what the survey measured and what the ad says. Citing the source is not sufficient. Noting that it was an image survey does not cure it.

05 — "Beauty ingredient"

When a cosmetic names an ingredient, it must state why the ingredient is there, and the stated purpose must sit inside the permitted efficacy range. As of the July 2026 revision to the industry advertising guideline, "beauty ingredient" and "skin-beautifying ingredient" are listed as unacceptable purposes. "Moisturising ingredient" is fine. The vocabulary changed; most pages have not.

Bonus — the subscription checkout

If you sell on subscription, the final confirmation screen is separately regulated. Showing one month's quantity for a five-month commitment does not count as disclosing the quantity. A cancellation phone number that does not actually connect can itself be a misrepresentation. This one is invisible in an ad review, because it lives in your cart software.

Each of the above corresponds to entries in the rule database described below, with the underlying notice or report cited. Happy to share the specific citations on request.

Who I am

A pharmacist, not an agency.

I am Masa, a pharmacist licensed in Japan. I have worked on advertising and labelling review for health foods, supplements, cosmetics, quasi-drugs and medical advertising since 2017 — roughly a thousand reviews. Every review is done by me. There is no account manager between you and the person making the judgement.

Licensed pharmacist (Japan)

Pharmaceutical Affairs Law Manager

Premiums & Representations Act, Grade 1

YMAA / KTAA certified

Cosmetics Pharmaceutical Affairs Manager

I maintain my own rule database. It currently holds 822 entries, each tied to a primary source — a ministry notice, an agency report, a cease-and-desist order — and each updated when the source moves. It is not a keyword blocklist. It exists because Japanese advertising rules change through notices rather than statutes, and a review written against last year's understanding is worth very little. The July 2026 cosmetics guideline revision in example 05 was in the database within weeks of publication.

Scope

What I do, and what I deliberately do not.

I do

Review of Japanese-market copy — landing pages, packaging, Rakuten and Amazon listings, ads, influencer briefs — against the applicable statutes, returned as a specific rewrite rather than a list of objections.

Pre-launch claim scoping: what this formulation can and cannot say in Japan, before the creative is made.

Ongoing review as notices are issued and copy changes.

I do not

Cosmetics or quasi-drug notification, importer licensing, or acting as your Marketing Authorisation Holder. Those require a full-time resident officer and are properly handled by the specialist firms that do them.

If you have not yet appointed an MAH, that comes first and I am not the right call. If you already have one and are now writing the Japanese page, that is exactly where I fit.

Working language and format. Everything is delivered in writing, in English, over email or a shared Slack channel. This is a design decision, not a limitation: a compliance judgement that is not written down is not usable later — by your team, by your agency, or by a regulator asking how you arrived at the claim.

Contact

Send me a page and I will tell you what is wrong with it.

The fastest way to judge whether this is useful is to give me something real. Send one Japanese landing page, product page or label, and I will return a short review of it — the specific lines, the statute each one touches, and what you could say instead. No charge for the first one.

I also work with regulatory consultancies whose clients raise the copy question after notification is complete. If that describes you, say so and I will reply on that footing.

[email protected]

M.and.A.works · Japan · Replies in English, usually within two business days.