Japan Issued Instructions for Advertising Quasi-drugs with Wrinkle Improvement Claims

On August 30, 2024, the Japan Cosmetic Industry Association (JCIA) issued a new instruction regarding the advertising of quasi-drugs that have wrinkle improvement claims. The instruction emphasizes the importance of accurately representing approved effects and provides five key points for compliance.

1. Advertisements must clearly reflect the approved efficacy of "wrinkle improvement."

Expressions such as "for wrinkles" or "for bothersome wrinkles" may create ambiguity and could mislead consumers into thinking that the product offers preventative or corrective benefits beyond its approved claims. Therefore, these expressions should be optimized.

2. Any explanations related to wrinkle grading or efficacy evaluation tests are prohibited, as they are deemed to be guarantees of effectiveness.

3. While improvements in age-related wrinkles can be advertised, claims suggesting rejuvenation or prevention of aging due to wrinkle improvement are not permitted.

4. Any claims regarding the degree of improvement must remain within the factual scope.

Specifically, expressions related to improvements in "deep wrinkles" are not allowed, because improvements to the extent of "deep wrinkles" are not clinically recognized

5. Advertisers must ensure that their explanations of the mechanisms of action for effective ingredients in wrinkle improvement do not go beyond the information included in approved application materials.

It is crucial to avoid any misinterpretation that may lead consumers to believe that these mechanisms of action have been approved as efficacy claims.

Besides, JCIA has previously issued guidelines regarding advertising claims for cosmetics, providing further explanations on aging care, including definitions, scope, and specific claim examples. Importers can use these guidelines to gain insight into the limitations and considerations for product claims in the Japanese market, which can help prevent compliance issues in the future.