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Food Labeling and Advertising RegulationLooking across packaging, e-commerce and advertising, our attorneys check compliance with the Food Labeling Standards and the range of claims you can make for health foods.

Free consultation Why LegalAgent
Response time
1 business day*
First consultation
30 min free
Scope
Food labeling · Health food ads · Premiums and Representations Act

* As a rule, for contract reviews and routine legal questions. For complex or urgent matters we propose a schedule that fits the matter.

Client companies served*

150+

Selected clients shown, in no particular order. * Clients and partners. Not limited to Food Labeling and Advertising Regulation matters.

KADOKAWA FRONTEO YAMAP ACROVE LAPRAS AVA Intelligence OPTIEUM Biotechnologies ReDelta Concrew LINEA Innovations TECHSUITE YStory

Checking food labeling and health food advertising before launch

We check labeling items such as ingredients, nutrition facts, allergens and use-by and best-before dates against the Food Labeling Standards, and set packaging, e-commerce and advertising displays side by side to identify inconsistencies between media and expressions to revise before launch. For health foods, we check the range of claims permitted under the Foods with Health Claims system based on the product category and supporting materials.

  • Launch is near, but the food labeling check keeps getting put off
  • Which health food claims you can use varies from person to person
  • The e-commerce marketplace listing and the packaging do not match
  • Supporting materials for country of origin labeling are not in place internally

Why LegalAgent

With LegalAgent, you can identify labeling fixes before print submission

We support your launch preparations in three ways: fast answers, fees you know before we start, and review results your staff can use as they are.

  1. 01Speed

    Typical law firms3–5 business days

    LegalAgent1 business day, as a rule

    Pre-submission checks, done in a set order

    We answer contract reviews and routine legal questions within one business day as a rule. When the print submission or publication date is close, we ask about your preferred timing and propose the scope and order of review.

  2. 02Fees

    Hourly billingTotal unknown at the start

    LegalAgentScope and fee set before we start

    Fees shown up front, based on products and media

    We ask about the number of products and display media to review, whether there are health food claims, and the state of your supporting materials, and give you an estimate before we start. Matter-based work is generally on a fixed fee.

  3. 03Deliverables

    • Review results by labeling item
    • Cross-media labeling comparison table
    • Alternative expressions
    • Labeling checklist

    Results delivered in a form your staff can use

    In addition to review results for each labeling item, we provide a cross-media comparison table and points for your e-commerce staff to confirm. We can also prepare a labeling checklist for internal use before launch.

* Response times are for contract reviews and routine legal questions; they vary by matter.

How it works

The AI Agent cross-checks the labeling; attorneys decide the range of expressions

The AI Agent organizes labeling items, cross-checks them across media and drafts revisions; attorneys judge compliance with the Food Labeling Standards and the range of expressions usable for health foods.

AI Agentdoes the work

  • Organizes labeling items from draft packaging, e-commerce and advertising
  • Extracts inconsistencies between media and expressions that need support
  • Drafts revisions, alternative expressions and notes

Attorneysmake the judgment

  • Check compliance with the Food Labeling Standards item by item
  • Decide usable expressions from the product category and supporting materials
  • Take responsibility for the final revisions and alternative expressions
ConsultationRevisions and checklist delivered
  1. STEP 01Reviewing product information and display media

    We organize the product category, the display media and the labeling items that need to be checked

    Scope of review and response schedule

  2. STEP 02Checking risks for each labeling item

    We check each labeling item from the perspectives of the Food Labeling Standards, the Premiums and Representations Act and the range of claims for health foods

    Review results by labeling item and a list of points requiring revision

  3. STEP 03Presenting draft revisions and alternative expressions

    We organize alternative expression proposals that take persuasive appeal into account and any necessary notes

    Draft revisions and alternative expression proposals

  4. STEP 04Reflecting results in the labeling check framework

    We organize labeling checklists by product category and an internal consultation route

    Labeling checklist and draft operating flow

  • Attorneys make the final callAn attorney checks every deliverable and takes responsibility for it.
  • Your inputs are not used to train AIOn top of attorneys' statutory duty of confidentiality, we work in an environment where your inputs are not used to train AI.
  • An AI Agent built in-houseOur own engineers develop it. Information Security Policy

Use cases

Common requests and what you receive

For each product category and review situation, we summarize the flow from the starting point of the consultation to the deliverables.

  1. 01

    The packaging design for a new food product is nearly finalized, but compliance with the Food Labeling Standards has not been checked before launch

    If left aloneThe product is launched with deficiencies in ingredient, nutrition facts or allergen labeling, requiring labeling corrections or reprinting

    What we doWe review the product characteristics, ingredients and draft packaging, and check compliance with the Food Labeling Standards item by item

    What you receive
    • Review results by labeling item
    • List of labeling points requiring revision
    • Review memo before packaging is finalized

  2. 02

    You cannot judge how far you can use functional expressions such as "good for the body" or "improves" in health food or supplement advertising

    If left aloneExpressions may be regarded as claiming pharmaceutical efficacy, leading to findings regarding advertising displays

    What we doWe review the product category, its position under the Foods with Health Claims system and the supporting materials, and individually check the range of expressions permitted under the system

    What you receive
    • Advertising expression review results
    • Alternative expression proposals
    • Points to confirm regarding supporting materials

  3. 03

    The labeling on an e-commerce marketplace product page differs from that on the packaging

    If left aloneLabeling that differs by medium leads to findings of misleading representations as to quality or terms and to a loss of consumer trust

    What we doWe review the packaging, e-commerce and advertising displays side by side, and organize content consistency and the labeling required for each medium

    What you receive
    • Cross-media labeling comparison table
    • Draft revisions
    • Points to confirm for e-commerce staff

  4. 04

    You want to organize the basis for country of origin and production area labeling, but the materials needed to confirm it are not available internally

    If left aloneLabeling continues while the basis for country of origin labeling is unclear, leading to findings such as misleading representations as to quality

    What we doWe review the procurement routes for ingredients and the materials on hand, and organize the range that can be labeled and the materials that are missing

    What you receive
    • Country of origin labeling review results
    • List of additional materials to confirm

Scope of our food labeling and advertising regulation support

According to the product category and the media under review, we set out what we review, what judgments we make and what we return as deliverables.

Checking food labeling and e-commerce displays
For both packaging and e-commerce sites, we check compliance with the labeling items required by the product's characteristics.
  • Checking compliance with the Food Labeling Standards
  • Checking e-commerce site displays
Checking health food and functional claims
For health food and supplement advertising expressions, we check the permitted range in light of the product category and supporting materials.
  • Checking health food advertising expressions
  • Checking the range of functional claims
Checking Premiums and Representations Act and campaign displays
We check representations regarding the quality, ingredients, price and other aspects of food, and promotions conditioned on purchase.
  • Checking for misleading representations as to quality or terms
  • Checking campaigns and prize promotions
Developing a labeling check framework
We help build a framework that allows advertising agencies, sales departments and e-commerce staff to check matters themselves before launch.
  • Developing an internal labeling checklist

Our approach

What we focus on in Food Labeling and Advertising Regulation

In food labeling and advertising regulation matters, we focus on the following perspectives.

  1. 01

    Reviewing across packaging, e-commerce and advertising

    The Food Labeling Standards mainly cover packaging labels, but e-commerce displays and advertising expressions need to be checked from other perspectives. Rather than optimizing the labeling for each medium separately, we review with the consistency of labeling across media in mind.

  2. 02

    Checking the range of expressions while preserving persuasive appeal

    For health food advertising expressions, after confirming the permitted range, we consider alternative expressions that preserve as much persuasive appeal as possible. Rather than prohibiting expressions across the board, we check them according to whether supporting materials exist and the product category.

  3. 03

    Organizing labeling on the premise of whether supporting materials exist

    For country of origin labeling and functional claims, the range that can be labeled changes not only with the content of the labeling itself but also with whether supporting materials can be confirmed. We review the draft labeling together with the supporting materials.

  4. 04

    Coordinating with adjacent areas such as Advertising Review and healthcare legal

    Where advertising expressions in general that go beyond food-specific labeling, or determinations of whether a product qualifies as a pharmaceutical, are needed, we coordinate with the areas responsible for Advertising Review or Healthcare, Pharma and Medical Legal.

Pricing

Food labeling and advertising regulation fees

For checks of food labeling, health food advertising and e-commerce displays, we propose a scope of work after hearing about the products concerned and the media to be reviewed.

How fees are set

Scope and fee agreed before we start

Matter-based work is generally on a fixed fee. For complex or urgent matters, we propose a schedule and an estimate that fit the matter.

First consultation

A free 30-minute online meeting.

You can come to us before your documents are in order. Tell us what you know so far.

Free consultation

What we check before quoting

  • The number of products to be reviewed and the range of display media (packaging, e-commerce, advertising and the like)
  • Whether there are claims relating to health foods or functional claims
  • The state of country of origin labeling and supporting materials
  • The time remaining until launch or the desired date for labeling corrections
  • Whether building an ongoing review framework, such as an internal labeling checklist, is needed

The volume of work varies with the number of products reviewed, the display media and the claims made, so we propose a scope of work after hearing about the products concerned and the display media.

Team & Record

Attorneys who know business practice handle your matters

Contract reviews and drafts
2,000+
Client companies
150+
Startup legal matters
200+
Legal and investment DD
20+

* Approximate figures based on matters handled by our firm; actual figures vary by matter.

Engineers

Shinya Makita and Sota Miya build our product on the same team as the attorneys.

Practical guides to food labeling and the Premiums and Representations Act

Health food advertisingCosmetics and Health Food Advertising Under the PMD Act: Efficacy Claims, Testimonials, and Administrative Surcharges

An explanation of the 56 efficacy claims for cosmetics, how they differ from quasi-drugs, and function claims for health foods. We distinguish the application of Articles 66 and 68 of the PMD Act and look at reviewing advertisements, including testimonials and photographs, and responding to administrative surcharges.

Related practice areas

FAQ

Frequently asked questions

Can you check only the packaging labeling?

Yes. After hearing about the product features and the materials you have on hand, we individually check compliance with the Food Labeling Standards.

How much guidance can you give on the range of expressions that may be used in health food advertising?

After reviewing the product category, its position under the Foods with Health Claims system and whether supporting materials exist, we advise individually on the range of expressions permitted under the system. We cannot give blanket approval in advance for definitive efficacy claims.

Can we consult you before submitting packaging for printing or after sales have begun?

You can consult us at any stage, whether while considering the packaging design, just before print submission, or when reviewing the labeling of products already on sale.

How does this differ from Advertising Review?

Advertising Review covers checks of advertising expressions, campaigns and stealth marketing displays regardless of industry. This page focuses on labeling regulation specific to food, such as the Food Labeling Standards and the range of claims for health foods. We also handle consultations spanning both.

Can you also determine whether a product qualifies as a pharmaceutical or medical device?

Determining whether a product qualifies as a pharmaceutical or medical device is handled on the Healthcare, Pharma and Medical Legal page. Regarding the boundary between labeling as a food and claiming pharmaceutical efficacy, we coordinate and review as necessary.

Can we consult you even if our supporting materials are not in order?

You can consult us at a stage when supporting materials have not yet been prepared. Together with the labeling content, we organize which materials should be confirmed.

Can you respond when print submission or advertising placement is imminent?

We also handle reviews on tight timelines. Because the possible timing depends on the volume to be reviewed, please first let us know your desired timing.

Can we engage you only to develop a labeling checklist?

We also accept engagements limited to developing labeling checklists by product category and internal consultation routes, without reviewing individual products.

Contact

Talk to us about food labeling and health food advertising

Please share the materials you have at this point, such as the draft packaging for the product you want checked, ingredient information and advertising expressions.

  • A free 30-minute online first meeting
  • You can consult us before your supporting materials are in order
  • We help from the packaging design stage to reviews of products on sale