Japan's advertising law: what the recent enforcement actually targets

For the Premiums and Representations Act — Japan's advertising law, administered by the Consumer Affairs Agency (CAA) — it is not enough to follow amendments to the statute itself. What matters in practice is the CAA's published market studies and the pattern of its cease-and-desist orders, commitment procedures and administrative guidance. In recent years the agency has published studies on No.1 claims, on buy-back services and on environmental labels, and in 2026 it issued orders on time-limited price claims and on stealth marketing on social media.

What these cases show is that it is not sufficient to ask whether each individual statement is literally true. The question is what impression the advertisement as a whole gives to the general consumer. This article sets out the representations most likely to be challenged, against the CAA's recent studies and enforcement.

The short version

• For environmental claims, abstract wording such as "ECO", "green" or "made with recycled material" is not enough. What the claim covers, the percentage used, the reduction achieved and the evidence behind it all need to be clear.
• No.1 claims and "recommended by X% of doctors" claims are not supported merely by holding a survey firm's result. The survey method has to correspond to what the advertisement says.
• "Only now", "until [date]" and similar time-limited claims require that the terms really are better during that period.
• For social media posts, where the business commissioned the post, provided consideration or was involved in setting its direction, it has to be clear to the general consumer that the post is advertising.

1　Recent developments

Over the past few years the CAA has published a series of market studies on themes that recur in advertising practice: the study on No.1 claims (September 2024), on buy-back services (April 2025), and on environmental labels (August 2026).

These studies do not create new prohibitions. They do show, concretely, which representations the CAA regards as problematic and how it analyses them under the Act, which makes them a practical reference point for advertising review.

The enforcement figures for fiscal 2025 give a sense of scale: 454 investigations, 13 cease-and-desist orders, 8 approved commitment plans and 388 instances of administrative guidance. A substantial share of matters is therefore resolved through guidance that is not published as an order. At a press conference the CAA Secretary-General attributed part of the increase in guidance to online monitoring begun in fiscal 2024.

Sources: CAA market studies; CAA, enforcement of the Premiums and Representations Act in fiscal 2025.

2　"ECO" and "environmentally friendly" are not enough

The environmental labels study published on 20 August 2026 is likely to have a substantial effect on advertising practice. The CAA collected 139 environmental labels used on business websites and e-commerce sites, interviewed the businesses concerned and surveyed 1,000 consumers.

Of the 139 labels, 20 did not make clear whether the environmental attribute related to the product itself, to the packaging, or to the whole. Of the 62 labels claiming an environmental attribute for raw materials, 29 did not state the percentage used as a specific figure — while 73.0% of consumers surveyed assumed that the percentage would be around 50% or more.

In 59 of the 139 cases, no explanation accompanied the label, so what exactly was environmentally responsible was not apparent on the face of it. The CAA also set out points to note about labels consisting only of words such as "ECO" or "green", or of nature-themed illustrations, without making the substance of the environmental attribute clear.

What to check in practice

• What the environmental attribute relates to: the product itself, the packaging, the manufacturing process.
• The percentage of recycled or bio-based material actually used.
• Where a claim such as "plastic reduction" is made, the reduction rate.
• Whether you hold data corresponding to the environmental effect as claimed.
• Whether your own mark is designed in a way that could be taken for third-party certification.

A claim that a product is "made with recycled material" may be literally true and still raise an issue under the Act if the actual scope or percentage is limited while the impression given is that the product is largely or wholly made of recycled material. Environmental claims work when they specify what is environmentally responsible, to what extent, and over what scope.

Source: CAA, study on environmental labels (summary).

3　"No.1 in customer satisfaction" — check the survey, not just the result

The CAA's September 2024 study on No.1 claims sets out the view that a survey relied on for a No.1 claim based on subjective evaluation should at least satisfy four conditions: ① the compared products or services are appropriately selected; ② the respondents are appropriately selected; ③ the survey is conducted by a fair method; and ④ the claim corresponds appropriately to the survey result.

Receiving a "No.1" result from a survey firm is therefore not the end of the analysis. If "No.1 in customer satisfaction" is claimed on the basis of a survey answered largely by respondents who only viewed the website rather than by actual users, the correspondence between the claim and the method is in question.

The interviews in the same study record that many advertisers were not aware of the basic content of the underlying survey — the questions asked, or which competing products formed the comparison set. Even where the work is outsourced to a survey or consulting firm, the advertiser needs to check the evidence and the survey design itself.

Source: CAA, study on No.1 claims (summary).

4　"Only now", "until [date]" — is it really time-limited?

On 11 June 2026 the CAA issued a cease-and-desist order against Geo Store Corporation over its buy-back service for smartphones and tablets, which had been advertised with claims such as "buy-back price up 10% — campaign running now" and "until [date]". The agency found the claims to be misleading as to advantageousness.

According to the CAA, the representations conveyed that a better uplift was available only to customers applying within the stated period. In fact, customers applying after the deadline received the same uplift or a better one.

The lesson is that stating a campaign period is not itself sufficient. "Only now", "today only", "until [date]" and "best to apply during the campaign" all convey that terms better than the usual ones are confined to that period. Where a campaign is repeatedly extended, or where equal or better terms are offered on an ongoing basis after it ends, the representation has to be revisited against the facts.

Source: CAA, cease-and-desist order against Geo Store Corporation.

5　Posts that do not look like advertising — stealth marketing

In social media marketing, posts whose advertising character is unclear remain an exposure. On 6 August 2026 the CAA issued cease-and-desist orders against two businesses providing services for the photo-editing app "SNOW", finding that the stealth marketing notification applied.

According to the published materials, SNOW Japan asked third parties to post on X in line with directions it gave, on condition that consideration was provided. The CAA found that the posts did not disclose that they had been commissioned by the business, and that, taken as a whole, it was not clear to the general consumer that they were the business's own representations.

Typical influencer advertising is not the whole of the exposure. Posts accompanied by free products, payments or loyalty points, ambassador programmes, posts styled as ordinary user content, and posts by employees or associates all require the same two questions: was the business involved in deciding the content, and can the general consumer clearly recognise the post as advertising?

Where a "PR" or "ad" label is used, it has to be placed where consumers can readily see it — not buried at the end of the post or inside a block of hashtags.

Source: CAA, cease-and-desist orders against two providers of services for the "SNOW" application.

6　Performance claims — hold the evidence first

Where the effect or performance of a product is claimed specifically, the substantiation rules apply. In April 2026 the CAA issued cease-and-desist orders against two sellers of incontinence underwear, finding representations to the effect that up to 100 cc or 200 cc of urine would not leak through the product to be misleading as to superiority.

Material submitted by one of the businesses was found not to constitute a reasonable basis for the claim; the other did not submit material within the period allowed.

The point of the substantiation rules is that the reasonable basis corresponding to the claim must exist when the claim is made, not be assembled after the agency raises the issue. Even where test data exists, it may not be treated as sufficient if the test conditions or what was measured do not correspond to the wording actually used. The same applies to claims such as "100% accurate" or "the highest accuracy in the industry" for a generative-AI feature — a point also covered in the legal checklist for launching a generative-AI service.

Sources: CAA, cease-and-desist orders against two sellers of incontinence underwear; guideline on the substantiation rules.

7　A pre-publication checklist

Taken together, the recent studies and orders point to reviewing not the single sentence under discussion but the impression the advertisement as a whole gives — including images, footnotes, price, period and how it appears on social media.

Where paid plans or subscriptions are sold online, the distance selling rules of the Act on Specified Commercial Transactions apply in parallel, including the requirements for the final confirmation screen.

8　In conclusion

The advertisements that get challenged have something in common: each individual statement may be literally true, while the impression the advertisement as a whole gives the general consumer diverges from the facts.

"Made with recycled material" may be accurate and still be a problem if the scope or percentage is small but the claim reads as though the material is used throughout. "Limited period" diverges from the facts unless the terms in that period really are better. And neither a survey firm's No.1 result nor a commissioned influencer post resolves the question on its own.

When launching a service or a campaign, the review question is not only "is this sentence true?" but "what impression does the whole — screen, images, footnotes, price, period and posting method — give the general consumer?"

Principal sources

• CAA, market studies
• CAA, study on environmental labels (summary)
• CAA, study on No.1 claims (summary)
• CAA, cease-and-desist order against Geo Store Corporation
• CAA, cease-and-desist orders against two providers of services for the "SNOW" application
• CAA, cease-and-desist orders against two sellers of incontinence underwear
• CAA, enforcement of the Premiums and Representations Act in fiscal 2025

Guidelines and notifications on advertising and representations are collected in the guideline index for advertising; to search across fields, use the index filterable by industry and function. These documents are published in Japanese.

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This article organises the general position as at September 2026 on the basis of published materials, and is not legal advice on any specific matter. Any particular representation requires analysis against the product or service, the medium and the composition of the advertisement as a whole. For advice on advertising review or campaign design for the Japanese market, please use the contact form.