Implying a doctor certified it is a prohibited ad
Japan’s PMD Act treats advertising, describing or circulating statements that lead to the false impression that a physician or other person has certified the efficacy, effects or performance of a cosmetic as falling within its prohibition on false or exaggerated advertisement, and that prohibition binds any person rather than only the seller.
The dermatologist endorsement is the single most portable device in Western beauty marketing and it is the one that does not port here, and because the rule reaches any person it reaches the affiliate and the paid creator too.
- Limits how to read US brands cite a person, Korean brands cite a test
87 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Article 66(2) is repealed or amended to remove the certification limb, or the Ministry states that professional endorsement of a cosmetic does not engage Article 66.
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
(2) It is to be construed as falling under the preceding paragraph to advertise, describe or circulate such statements as lead to the false impression that a physician or other person has certified the efficacy, effects or performance of pharmaceuticals, quasi-pharmaceutical products, cosmetics, medical devices or regenerative medicine products.
The Japanese original reads ２ 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効能、効果又は性能について、医師その他の者がこれを保証したものと誤解されるおそれがある記事を広告し、記述し、又は流布することは、前項に該当するものとする。 The operative Japanese phrase is 誤解されるおそれがある, which is a risk-of-being-misunderstood test rather than a proof-of-falsity test.
Read 2026-08-05 · Open government · page hash
a01b624828ba - 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.
Quoted for two words. 何人も, rendered here as “no person”, is what extends this beyond the marketing authorisation holder to anyone circulating the statement.
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
“Implying a doctor certified it is a prohibited ad”, The Orbt Market Index 0.1.0, entry omr:jp:implying-a-doctor-endorsed-it-is-exaggerated-advertising, retrieved September 9, 2026, https://tryorbt.com/markets/entry/jp--implying-a-doctor-endorsed-it-is-exaggerated-advertising. Dataset: https://doi.org/10.5281/zenodo.22679129
Orbt, "Implying a doctor certified it is a prohibited ad," Orbt Market Index, entry omr:jp:implying-a-doctor-endorsed-it-is-exaggerated-advertising, verified August 5, 2026, https://tryorbt.com/markets/entry/jp--implying-a-doctor-endorsed-it-is-exaggerated-advertising.
@misc{orbt-jp-implying-a-doctor-endorsed-it-is-exaggerated-advertising,
title = {Implying a doctor certified it is a prohibited ad},
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:implying-a-doctor-endorsed-it-is-exaggerated-advertising. Verified 2026-08-05},
howpublished = {\url{https://tryorbt.com/markets/entry/jp--implying-a-doctor-endorsed-it-is-exaggerated-advertising}},
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:implying-a-doctor-endorsed-it-is-exaggerated-advertising, with the same evidence and falsifier.
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