M&M, a Tokyo e-commerce company, sold Anrinkle, a quasi-drug wrinkle cream. Its advertising ran through affiliate sites — web media aimed at adult women, with articles like 'At-home permanent wrinkle erasure!? A doctor reveals...'. Inside: 'smooth and tight a few seconds after applying', 'aesthetic-medicine-level care at home!', 'eye area smooth in 10 seconds' and 'clinically effective on 98% of users', beside before-and-after photos suggesting that merely using the cream erased wrinkles around the eyes, mouth and neck in seconds.
When the Consumer Affairs Agency demanded substantiation, M&M submitted nothing within the deadline — the claims were presumed misleading. The agency also noted that M&M had left the ad content to affiliates and did not verify what they published. Tokyo had already issued a measure order over the same displays on 28 March 2023. The case became the first surcharge ever imposed on a quasi-drug since Japan's surcharge regime began.
On 2 December 2025 the CAA ordered M&M to pay 5,880,000 yen — 3% of the 196,324,953 yen of Anrinkle sales recorded between 2 July 2022 and 3 May 2023, while the offending articles ran from 2 July to 21 November 2022 — payable by 3 July 2026. The amount was modest; the precedent was not: quasi-drugs, the category between cosmetics and medicines, no longer escape the surcharge.
M&M left ad content to affiliates and filed no substantiation, so the CAA presumed the claims misleading and imposed Japan's first quasi-drug surcharge of ¥5.88M.
The ads implied medical-grade wrinkle erasure in seconds — including a 'clinically effective on 98%' claim — and M&M submitted no substantiation at all.
The content was written by affiliates; M&M delegated the displays and never verified what went live.
Tokyo's March 2023 measure order was followed by a national surcharge — the first ever for a quasi-drug.
Advertisers own what their affiliates publish: M&M's partners promised wrinkle erasure 'like aesthetic medicine', no proof was filed, and Japan's first quasi-drug surcharge followed.
The surcharge order of 2 December 2025 required M&M to pay 5,880,000 yen by 3 July 2026, on 196,324,953 yen of Anrinkle sales. Tokyo's measure order of 28 March 2023 had preceded it; the case was reported as the first surcharge on a quasi-drug.
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