(i) The Premiums and Representations Act
When companies conduct marketing toward general consumers, they are required to comply with various advertising and labelling regulations. Among other things, around forty orders for measures (i.e., administrative dispositions) are issued every year under the Premiums and Representations Act, and the publication or news reporting of such orders may threaten the subject products and services, and even the companies themselves. Therefore, we believe that companies should pay special attention to compliance with the Premiums and Representations Act.
Our firm has reviewed and advised on many advertising and labelling matters and has been involved in a number of investigation cases under the Premiums and Representations Act conducted by the Consumer Affairs Agency and other regulatory authorities, and thus, we have abundant experiences in matters related to advertising and labelling regulations. Practice under the Premiums and Representations Act is fast-moving, with the introduction of stealth marketing regulations and the publication of a fact-finding report on "subjective No. 1 labelling," influenced by the digitalization of consumer lifestyles, etc. We always keep on top of these developments, including following trends in execution [of regulations] to deepen our knowledge.
While many of the inquiries we receive on advertising and labelling plans need responses within a short period of time and sometimes require us to consider issues that have not been previously discussed, our firm will discuss the best policy for each case and provide advice and support based on our extensive experience and knowledge. In case of a problem with a labelling plan, for example, if there is a problem with the method of annotation or the contents of labelling, we will make every effort to provide an alternative solution by exercising our knowledge of the field, such as by considering alternatives based on the problematic portion. In addition, under the Premiums and Representations Act, companies are obliged to take "necessary measures," including establishment of necessary systems, to prevent violations. The necessary measures may vary depending on the products and services to be provided and the method of labelling, and we also provide consulting services for such measures.
In connection with the above, lawyers at our firm have authored the following books: "Act against Unjustifiable Premiums and Misleading Representations" (Shojihomu Co., Ltd., 2018), "Legal Consultations on the Act against Unjustifiable Premiums and Misleading Representations (Revised Edition)" (Seirin-Shoin, 2018 (co-author)), and "Guide Map of the Premiums and Representations Act for Those Engaging in Practices" (Shojihomu Co., Ltd., 2024). Furthermore, lawyers at our firm have served as members of the "Study Group of the Act against Unjustifiable Premiums and Misleading Representations" held by the Consumer Affairs Agency, and as members of "Tokyo Digital CATS," a team of advisors for the investigation conducted by the Tokyo Metropolitan Government regarding Internet advertising.
In this respect, one of our advisors, Wataru Kobayashi, was the previous Secretary-General of the Fair Trade Commission, and also served as Director General of the Economic Affairs Bureau and Director General of the Investigation Bureau of the said commission, Deputy Secretary General of the Consumer Affairs Agency, Director of the Consumer Policy Division, Commerce and Information Bureau, the Ministry of Economy, Trade and Industry, and other offices. He works with lawyers at our firm to optimally resolve issues from multiple perspectives.

(ii) Advertising and Labelling Regulations other than the Premiums and Representations Act
In addition to the Premiums and Representations Act, when advertising and labelling products, it is necessary to pay attention to various other regulations according to each product, etc.
For example, when advertising and labelling foods, including health foods, it is necessary to pay attention to the Act on Securing Quality, Efficacy and Safety of Products Including Pharmaceuticals and Medical Devices (even if such foods are not approved as pharmaceuticals), the Health Promotion Act, and other laws and regulations and, in case of containers and packaging for processed food, etc., the labelling must be made in accordance with the Food Labeling Act and Food Labeling Standards. In addition, for foods for specified health uses or foods with functional claims, it is necessary to understand the relevant systems. When advertising pharmaceuticals, quasi-pharmaceutical products, cosmetics or medical devices, a review is necessary based on the regulations, such as the Act on Securing Quality, Efficacy and Safety of Products Including Pharmaceuticals and Medical Devices and the Standards for Proper Advertising of Pharmaceuticals, etc. In the case of advertising or labelling for medical institutions, it is necessary to pay attention to the Medical Care Act. When conducting mail order sales, it is necessary to comply with the advertising regulations and the regulations on final confirmation screens under the Act on Specified Commercial Transactions. In addition to the above, there are various advertising and labelling regulations, all of which require a cross-sectional review based on many relevant administrative documents and guidelines.
In some cases, there may be concerns as to whether an act to mislead as to quality, etc., under the Unfair Competition Prevention Act or an act of deceptive inducement of customers under the Act on Prohibition of Private Monopolization and Maintenance of Fair Trade applies to the situation.
As a full-service law firm, we receive a wide variety of legal inquiries from clients involved in many types of businesses, and while handling a wide range of advertising and labelling regulations, we are constantly deepening our knowledge of the issues above. In connection with the above, lawyers at our firm have authored books such as "Thematic-based: Legal Practice in the Healthcare Business" (Chuokeizai-sha Holdings, Inc., 2023) and held seminars on labelling of foods, including foods with functional claims.

(iii) Regulations on Premiums
When companies conduct marketing campaigns, etc., they are also required to comply with the regulations on premiums under the Premiums and Representations Act. In addition to consultation on advertising and labelling, our firm provides consultation on many [types of] premium regulations, as we have a particular strength in handling complex cases such as point systems and implementation of campaigns involving multiple companies. In relation to premium regulations, we also provide advice and support tailored to each case, such as by providing alternative solutions.