Japan’s stealth marketing rules and PR labels
Since 1 October 2023, hiding the fact that content is advertising (stealth marketing) has been regulated in Japan as a misleading representation under the Act against Unjustifiable Premiums and Misleading Representations. Social posts made at a company’s request must make it clear to ordinary consumers that they are ads.
Who is covered
- Posts whose content the company (advertiser) was involved in deciding.
- The rules apply to the advertiser; creators are not directly regulated, but correct labelling depends on them.
- Not only payment: free products or other benefits can count, depending on how involved the company was.
How to label
- Use words that show it is an ad: “Ad”, “Advertisement”, “PR”, “Promotion”
- Put the label where people see it immediately, such as the start of the caption
- Don’t bury it among many hashtags or make it tiny or the same colour as the background
- In videos, also show it at the start or clearly on screen
If the rules are broken
The Consumer Affairs Agency can issue an order (publicising the violation and requiring measures to prevent recurrence). The first such order under these rules was issued in June 2024.
Related rules
Claims about cosmetics or health foods fall under the Pharmaceutical and Medical Device Act; overstating price or performance can also breach the misleading-representation rules of the same premiums act.
In Tonakai, AI checks scripts and posts for PR labels and risky claims, then a person signs off. Creators can also check the label in the app before posting.