Advertising Rules in Japan: Why Creative Gets Sent Back

Who reviews what

There is no general government pre-approval of advertising content in Japan. (Outdoor advertising structures themselves may need permits under local ordinances, but those are normally the media owner’s responsibility.) What a creative goes through instead is a review by whoever controls the space: the railway operator for station advertising and train advertising, the building owner or screen operator for digital billboards, the airport company, the taxi operator, the shopping centre. Each applies its own standards, and the contract typically gives it the right to decline a creative or ask for changes. This review is contractual, not a government approval.

Those standards are not arbitrary. They are built on top of the laws that apply to advertising in general, the voluntary codes of the industries concerned, and the operator’s own judgement about what its passengers, tenants or visitors should see. The practical consequence for an advertiser is that compliance with the law is necessary but not sufficient: a creative can be perfectly lawful and still be declined by a railway company because it resembles a station sign or makes a claim the operator does not want to carry.

Reviews are generally conducted in Japanese, and any Japanese copy is read closely. Timing varies by operator and format, and the review is one of the reasons the lead time for a campaign is counted in weeks rather than days. The guide for international brands describes where it sits in the overall process.

The laws behind most rejections

A small number of laws lie behind many of the changes requested from international advertisers. They are described here at a general level so that a creative team can recognise the risks early. This is general guidance, not legal advice; how a law applies to a specific claim is a question for legal counsel.

Misleading representations (景品表示法)

The Act against Unjustifiable Premiums and Misleading Representations is the law most often relevant to global creative. It prohibits representations that would mislead consumers into thinking a product or service is significantly better, or its price or terms significantly more favourable, than is actually the case or than a competitor’s. In practice this affects superlatives and ranking claims — "the best", "No.1", "the world’s most popular" — which need objective evidence the advertiser can produce if asked, and reviewers typically expect the source and basis of the claim to be stated in the creative. It also covers comparisons that are selective or cannot be substantiated, and the same Act regulates premiums such as prizes and giveaways. In our experience, a global tagline built on a superlative is one of the most common reasons a creative comes back.

Health, cosmetics and medical claims (薬機法)

The Act on Securing Quality, Efficacy and Safety of Products Including Pharmaceuticals and Medical Devices (often shortened to the Pharmaceuticals and Medical Devices Act) limits what can be claimed about the effects of pharmaceuticals, quasi-drugs, cosmetics and medical devices. Supplements and health foods that are presented as having drug-like effects can also fall within it. For cosmetics in particular, the range of effects that may be claimed is narrow; a phrase such as "repairs skin", "clinically proven", "burns fat" or "cures" that is routine in other markets is often not acceptable here and is likely to be questioned in review. Advertising by clinics and other medical institutions is also restricted under the Medical Care Act and the Ministry of Health, Labour and Welfare’s medical advertising guidelines (医療広告ガイドライン), which restrict patient testimonials and claims of superiority and limit the use of before-and-after photographs.

Alcohol and age-related content

Alcohol advertising is governed largely by the alcohol industry’s own voluntary code, which covers how drinking is depicted, warnings such as those about drinking during pregnancy and drink-driving, and the age of the people shown — no models under 20, with stricter age rules for television. The code itself rules out some transit formats for alcohol, including vehicle exterior ads, whole-car exclusive interiors, ticket-gate stickers, and stair stickers and pillar wraps inside station gates, and it keeps large outdoor boards away from the immediate surroundings of schools. Railway operators and landlords may add their own restrictions on top.

Financial products (金融商品取引法 and related rules)

The Financial Instruments and Exchange Act requires advertising for investment products to include disclosures such as the provider’s name and registration, fees and the risk of loss, and restricts misleading descriptions of returns; lending and insurance advertising have their own rules. A creative for a financial service that relies on a headline figure or a promise of returns will be reviewed closely, and the required disclosures can take more space than a short screen spot easily accommodates.

Outdoor advertising ordinances (屋外広告物条例)

Under the Outdoor Advertisement Act, prefectures and certain cities set their own outdoor advertisement ordinances. These govern where outdoor advertising may be placed, its size and illumination, in some areas its design, and when a permit is required. They are a major reason building wraps and scaffolding graphics are tightly controlled and why a format available in one district may not be available in another. Permits are normally the media owner’s responsibility at the site level, but the ordinances shape what inventory exists in the first place.

Railway and landlord house rules

The second layer of review is the operator’s own standards, and these are where an otherwise lawful creative is most often declined. The themes are consistent across operators even though the wording differs.

• Nothing that could be mistaken for wayfinding. Arrows, pictograms, colour schemes and layouts that resemble station signage are typically refused in stations, because they can confuse passengers.
• Nothing unsafe. Imagery that could startle, that depicts dangerous behaviour on platforms or roads, or that could distract drivers near a road is likely to be declined.
• Superlatives and comparisons. Some operators set stricter conditions than the law — for example requiring a comparison to be substantiated by a public body or an independent third party — or discourage comparative claims altogether.
• Category exclusivity. Some operators carry exclusivity arrangements for a category in a space, and some decline competing creative for a period.
• Sound, motion and brightness limits. Full-motion video, flashing and audio are restricted by site, and the limits are often tighter in stations than on street-facing screens.
• Political, religious and campaigning content is often restricted, as is anything likely to cause offence to the general passenger.
• Decency and public order. Standards here are conservative by the measure of many Western markets, particularly for imagery seen by children on their way to school.

What this means for a global master creative

Most international campaigns arrive in Japan as an adaptation of a global master. In our experience, these are the elements that most often need to change.

• Comparative and superlative claims. "Better than", "No.1" and "the best" generally need objective substantiation, with the basis stated in the creative, or should be removed.
• Celebrity and likeness rights. Permission to use a person’s image is checked by territory and by medium; a global contract does not always cover Japanese outdoor advertising, and reviewers may ask for confirmation.
• Before-and-after imagery. Common in beauty and fitness advertising elsewhere, and frequently questioned here under the health-claim and medical advertising rules.
• "Clinically proven", "dermatologist recommended" and similar. Restricted for cosmetics and health products, and acceptable, if at all, only with careful wording and substantiation.
• QR codes and URLs. Generally permitted, but their placement and size are reviewed, and in stations anything that invites passengers to stop in a flow of people may be questioned.
• Bilingual copy. English headlines are common and accepted; a Japanese line that carries the claim is usually expected, and the review is of the Japanese.
• Local legal notices. Disclaimers, source lines for claims and age warnings need to be legible at the size and distance of the placement.

The efficient approach is to adapt the master once, for Japan, with these points in mind, and to have the Japanese copy written by someone who writes advertising rather than translated line by line. A creative prepared this way is more likely to pass review on the first submission.

A pre-flight checklist

Before a creative goes to the operator, we check it against the following. Running the same list internally before you send it to us reduces the back-and-forth.

• Every superlative, ranking or comparison has evidence the advertiser can produce, and the basis is stated in the creative.
• No efficacy claims for cosmetics, supplements, health products or medical services beyond what the applicable rules allow.
• Rights to every person, image, piece of music and font are cleared for outdoor use in Japan for the campaign period.
• Nothing resembles station or road signage: no arrows, pictograms or sign-like colour blocks.
• No depiction of unsafe behaviour on platforms, in trains or on roads.
• Alcohol, financial and age-restricted content carries the required warnings and disclosures at a legible size.
• Motion, flashing and sound are within the limits of each site the creative will run on.
• The Japanese copy has been reviewed by a copywriter, and the claim it carries matches the English.
• Legal notices and disclaimers are readable at the viewing distance of the placement.
• Files are prepared to each site’s specification, with safe areas respected.