Advertising Rules in Japan for Foreign Brands:
Misleading Claims, Stealth Marketing and TikTok/Meta Ad Review (2026)

Do Japan's advertising rules apply to foreign brands?

Yes. Japan's core advertising law, the Premiums and Representations Act (Act against Unjustifiable Premiums and Misleading Representations, often shortened to Keihin Hyoji Ho or Keihyoho), regulates representations made to consumers in Japan. What matters is who sees the ad and who sells the product, not where the advertiser is incorporated. If you run a TikTok or Meta campaign targeting Japan, sell through a Japanese app store listing or ship to Japanese customers, your ads, landing pages and social posts are in scope.

The 2023 amendment, in force since October 1, 2024, made this explicit for cross-border cases. It added rules for serving cease-and-desist orders abroad and a framework for the Consumer Affairs Agency (CAA) to share information with foreign enforcement authorities, citing the need to address misleading representations by foreign businesses aimed at Japanese consumers.

Enforcement is active. In fiscal 2025 (April 2025 to March 2026) the CAA issued 13 cease-and-desist orders, approved 8 commitment plans, issued 10 surcharge payment orders totaling ¥339.4 million and handled 388 cases with administrative guidance. Many of these cases come down to wording: a claim, price or deadline shown in a misleading way.

The Premiums and Representations Act: three kinds of misleading representations

Article 5 of the Act prohibits three types of representation. "Representation" is broad: it covers video, narration, on-screen text (telop), captions, banners, landing pages, app store copy and social posts.

You must be able to prove performance claims, fast

Under the substantiation rule (Article 7(2)), when the CAA suspects a quality or performance claim is misleading, it can ask the advertiser to submit materials showing a reasonable basis. The deadline is, in principle, 15 days from the written request, and the need to run a new test is not accepted as a reason for extension. If you cannot submit adequate evidence in time, the claim is deemed misleading for the purpose of a cease-and-desist order.

The lesson: keep evidence for every claim on file before launch, and check that it supports the claim as a Japanese viewer reads it.

No.1 claims, price comparisons and "limited time" offers

"No.1" and "satisfaction" claims need a fair survey

"Customer satisfaction No.1" style claims are common in Japanese advertising, and they are a recurring enforcement target. The CAA notes that in fiscal 2023, 13 of the 44 businesses that received cease-and-desist orders were involved in No.1-related representations, typically based on "image surveys" where respondents simply looked at websites and picked an impression. In its September 2024 report, the CAA set out four conditions a No.1 claim needs to be backed by a reasonable basis:

1. Fair comparison set: the main competing products or services in the category are included.
2. Right respondents: if the claim implies actual users (for example "customer satisfaction"), the respondents must be actual users. A footnote saying it was an image survey does not fix the mismatch.
3. Fair method: no steering, such as fixing your product at the top of the list or stopping the survey when you reach first place.
4. Claim matches the result: the wording on screen corresponds to what the survey actually measured.

The same thinking applies to "X% of experts recommend" claims. If you cannot meet these conditions, drop the ranking and use a concrete, verifiable fact instead.

Price comparisons: the "8-week" rule of thumb

Showing a struck-through former price next to a sale price is a "double price" representation. The CAA's pricing guideline treats a former price as safe to compare against if it was the price "for a reasonable recent period." As a general benchmark, that means the item sold at that price for more than half of the 8 weeks before the sale started (or of the selling period, if shorter). It does not qualify if the total period at that price was under 2 weeks, or if 2 weeks or more have passed since the item was last sold at that price.

Comparisons with a future price ("¥X after launch") are risky unless you will certainly sell at that price, and "market price" comparisons need a verifiable basis.

"Limited time" and countdown offers must really end

A deadline is a trading term. If the same or better deal remains available after the stated end date, the deadline misleads. In June 2026, for example, the CAA issued a cease-and-desist order over social media posts announcing a buyback campaign "until" a given date; the campaign was rolled over period after period, and customers could get the same or better rate after each deadline. For performance ads that refresh every few weeks, plan offers and creatives together so the telop never promises an ending that does not happen.

Penalties: cease-and-desist orders, surcharges and criminal fines

The consequences go beyond a rejected ad:

• Cease-and-desist order (sochi meirei): the business must stop the representation, publicly notify consumers that it was misleading and put prevention measures in place. Orders are published on the CAA website with the company name.
• Surcharge: for misleading quality or terms, the surcharge is 3% of sales of the product or service during the relevant period, capped at the most recent 3 years. Since October 2024 the rate rises to 4.5% for businesses that received a surcharge order within the previous 10 years. No surcharge is imposed if the calculated amount is under ¥1.5 million.
• Criminal penalty: since the 2024 amendment, intentionally making a misleading quality or terms representation can be punished with a fine of up to ¥1 million, with penalties also applicable to the company.
• Commitment procedure: also new since October 2024, a business suspected of a violation can propose a corrective plan. If the CAA approves it, no order or surcharge is issued, but the approval and an outline of the case are published.

For a brand entering Japan, the reputational cost of a published order often outweighs the money.

Stealth marketing: the short version

Since October 1, 2023, advertising that hides its commercial nature has been a designated misleading representation under the same Act. Key points:

• The advertiser is regulated, not the influencer or creator who posts.
• It covers posts the advertiser effectively controls, even without written instructions, and can cover employee posts.
• Disclosure must be clear: "advertisement," "PR" or "sponsored," shown where and when viewers will notice it. Burying "#PR" in a block of hashtags or flashing it at the end of a long video is not enough.

Paid ads carrying the platform's "Sponsored" label are clearly ads; the risk sits in organic creator posts, gifted campaigns and testimonials on your own site. For the full rules, platform disclosure settings and a pre-engagement checklist, see our guide to UGC and influencer ads in Japan.

Platform ad review in Japan: TikTok and Meta

Legal compliance and platform approval are two separate gates. An ad can be lawful and still be rejected, and an approved ad can still breach Japanese law. TikTok, for example, states that advertisers are responsible for their ads and must comply with local laws in the regions they target.

How review works

• TikTok: most ads are reviewed within 24 hours, though some take longer. Review covers the video, ad text and landing page. Editing and saving the creative triggers a new review, and you can open an Advertiser Support ticket if you believe a rejection was a mistake.
• Meta (Facebook, Instagram): ads are typically reviewed within 24 hours. Review covers images, video, text, targeting and the landing page. An edited ad is reviewed again as a new ad, and you can request another review through Account Quality. Violations can also lead to restrictions on the ad account or Business assets.

In ZVA's experience running campaigns in Japan, ads in regulated categories such as finance, beauty or supplements can take 2 to 3 business days, and first submissions from new accounts may trigger additional business verification. We recommend finishing submission at least 3 business days before a fixed launch date.

Common rejection reasons we see in Japan

Repeated rejections delay learning, and both platforms can restrict accounts that keep violating policy. Fixing the script before shooting is far cheaper than re-editing.

Health, cosmetics and finance: specialist review required

Some categories sit under additional, stricter laws on top of the Premiums and Representations Act:

• Cosmetics, quasi-drugs, supplements, medical devices and health-related products: the Pharmaceutical and Medical Device Act (PMD Act) and related rules restrict what can be said about effects. Platforms also apply their own healthcare policies.
• Consumer lending, investment, FX, crypto-assets and insurance: the Money Lending Business Act, the Financial Instruments and Exchange Act, the Insurance Business Act and industry self-regulation set mandatory disclosures and prohibited expressions. Platforms often require licenses or pre-approval for financial advertisers.

This article does not give claim-level guidance for these categories. Any copy about effects, results or returns should be reviewed by a qualified Japanese specialist before production, and a good production partner builds that step into the schedule.

Practical checklist for Japanese video creatives

Most problems are visible in the script. Use this list when you review a Japanese script or edit.

Telop and disclaimers

The CAA's guidance on qualifying statements (uchikeshi hyoji) says a video disclaimer is judged by its size, its contrast with the background, how long the screen stays up relative to the amount of text, whether it appears on the same screen as the claim, and whether it is voiced when the claim is voiced. The headline must reflect reality; a disclaimer that contradicts it does not fix it.

Testimonials and UGC-style ads

The same CAA guidance notes that viewers who see a user testimonial tend to assume most people get similar results, and that "this is an individual's opinion" rarely changes that impression. If results depend on conditions, the conditions must be clear. For UGC-style ads with Japanese talent, write testimonials around experience and usability, keep them consistent with what the product reliably delivers, and never present scripted talent as independent customers. Our localization guide covers how to write Japanese hooks and telop that feel native without overstating.

Why foreign brands hand Japanese scripts to a local team

Translation tools cannot tell you that a phrase harmless in English reads as an absolute claim in Japanese, that a telop needs another second on screen, or that a "regular price" fails the 8-week benchmark. Those are line-by-line judgment calls, made in Japanese, before the shoot.

ZVA is a Fukuoka-based team specialized in vertical video ads. We plan, script, cast Japanese talent, shoot in our own studio and edit, and we also run TikTok, Meta and Google campaigns. For regulated products, our workflow looks like this:

Two honest caveats, which also appear on our pricing page: passing platform review is not guaranteed, and final decisions on ad expressions rest with the advertiser. What we can do is make rejections and legal risk much less likely by catching problems at the script stage. Production starts from ¥50,000 per video (overseas projects quoted individually), with delivery in as few as 5 business days, and we work in Japanese, English, Korean and Chinese. Performance-based ad operation plans are available.

Summary

• The Premiums and Representations Act applies to foreign brands advertising to Japanese consumers, with stronger penalties since 2024.
• The riskiest elements are No.1 claims, former-price comparisons, deadlines that never end, before-and-after footage, testimonials and fleeting disclaimers.
• TikTok and Meta review is a separate gate; health, cosmetics and finance need specialist legal review on top.

The most efficient place to manage all of this is the Japanese script. If you want vertical video ads for Japan written with these rules in mind, produced with Japanese talent and taken through platform review, ask ZVA for a quote. Tell us your product, target platforms and any claims you want to make, and we will tell you what we can say, how we would say it and what it will cost.