Implicit counts, and so does circulating it
The Japanese prohibition reaches statements made explicitly or implicitly, and reaches the acts of advertising, describing and circulating alike, so a claim about a cosmetic’s efficacy is caught by how it is likely to be read rather than by whether it was stated outright or by who published it.
Two of the three verbs describe things a brand does not pay for, so the compliance surface here is the affiliate brief and the reposted review rather than the advertisement, and those are the assets nobody routes past legal.
85 of a possible 97Tier A, primary document or measured outcome. Nothing at this tier is allowed past 97, however good it looks.
Verified August 5, 2026Rechecked every 365 days, next by August 5, 2027.
Held since August 5, 2026A rule, law or policy that limits what you may do or say. The earliest date we are willing to say this held. It may well have been true before that; we do not backdate a record past the evidence we have read. Supported, version 1.
This entry is wrong if
Article 66(1) is narrowed to explicit statements only, or to advertising by the marketing authorisation holder, or the words describe and circulate are removed.
Written before the record was published, not after. If you can show this, send it to hello@tryorbt.com and the correction goes on the record with the entry.
Evidence
- Tier Aregulation
Article 66 (1) No person must, explicitly or implicitly, advertise, describe or circulate false or exaggerated statements regarding the name, manufacturing process, efficacy and effects or performance of pharmaceuticals, quasi-pharmaceutical products, cosmetics, medical devices or regenerative medicine products.
Japanese original: 第六十六条 何人も、医薬品、医薬部外品、化粧品、医療機器又は再生医療等製品の名称、製造方法、効能、効果又は性能に関して、明示的であると暗示的であるとを問わず、虚偽又は誇大な記事を広告し、記述し、又は流布してはならない。 The three verbs are 広告し (advertise), 記述し (describe) and 流布 (circulate).
Read 2026-08-05 · Open government · page hash
a01b624828ba
History
- v1created
Entered 2026-08-05 from primary documents already held in the store, at the same content hashes recorded when they were first read. No new retrieval.
Append-only. Nothing in this list is edited or removed once written, including the entries that record our own mistakes. Every change to every record is on the corrections page, and the same log is in entries.json under revisions.
Cite this entry
“Implicit counts, and so does circulating it”, The Orbt Market Index 0.1.0, entry omr:jp:an-implicit-efficacy-claim-counts-as-an-ad, retrieved September 9, 2026, https://tryorbt.com/markets/entry/jp--an-implicit-efficacy-claim-counts-as-an-ad. Dataset: https://doi.org/10.5281/zenodo.22679129
Orbt, "Implicit counts, and so does circulating it," Orbt Market Index, entry omr:jp:an-implicit-efficacy-claim-counts-as-an-ad, verified August 5, 2026, https://tryorbt.com/markets/entry/jp--an-implicit-efficacy-claim-counts-as-an-ad.
@misc{orbt-jp-an-implicit-efficacy-claim-counts-as-an-ad,
title = {Implicit counts, and so does circulating it},
author = {{Orbt}},
year = {2026},
doi = {10.5281/zenodo.22679129},
note = {The Orbt Market Index 0.1.0 (dataset DOI 10.5281/zenodo.22679129), entry omr:jp:an-implicit-efficacy-claim-counts-as-an-ad. Verified 2026-08-05},
howpublished = {\url{https://tryorbt.com/markets/entry/jp--an-implicit-efficacy-claim-counts-as-an-ad}},
license = {Orbt Index Public Licence. Free to quote and cite; not to redistribute}
}For a deck, a brief or a chat.
Free to quote, cite and act on. Not to resell or redistribute — the sources ask that of us, and each one’s terms are named. Machine-readable: entries.json carries this record under the id omr:jp:an-implicit-efficacy-claim-counts-as-an-ad, with the same evidence and falsifier.
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