Freis Lab's 'NHK sold-out' serum ads — all three misrepresentation rules at once

Freis Lab sold the whitening serum 'Fraise Lab White VC Serum' by mail order. Ads reached consumers from Instagram posts to affiliate sites and claimed '＼NHK放送後、爆売れ中／' ('selling out after NHK broadcast'), '医療機関の皆様、言っちゃいます' ('to the medical institutions — we'll say it'), and three 'No.1' lines: the serum users want to keep using, the highest expectation, and the most recommended among vitamin C whitening serums.

A campaign claim offered the first purchase at 2,980 yen as a limited-time deal. Separately, the company commissioned multiple influencers through an intermediary to post about the product in exchange for consideration, then selected and displayed those posts on its own sales website without disclosing that the posts had been commissioned.

On 27 March 2026 the Tokyo Metropolitan Government issued an administrative order under Article 7(1) of the Act against Unjustifiable Premiums and Misleading Representations, finding a violation of all three representation types: Article 5(1) quality misrepresentation (effectiveness and 'No.1' claims), Article 5(2) advantageous misrepresentation (the limited-time campaign claim) and Article 5(3), the stealth-marketing notice (the undisclosed commissioned posts). Japanese compliance media described it as the first full-set finding since the 2024 stealth-marketing notice.

The order requires Freis Lab to notify consumers that the representations violated the Act, stop making similar representations, and put recurrence-prevention measures in place, communicated to officers and employees.