Pull Charm, an ecommerce company in Tokyo's Meguro ward, sold the hair tonic Ikumo Nano Grow Rich through websites reached from Instagram ads. The campaign carried five superiority-misleading claims, including 'the state has approved its hair-growth effect' and 'over 90% felt results'. The substantiation the company submitted was not accepted as reasonable grounds.
The proof had been manufactured. Before-and-after images were composites built from photos of thinning heads, not results of the product. Testimonials styled as SNS user posts were written by the ad agency. 'Nobel-class' hair growth borrowed from a decades-old Nobel Prize for vitamin research. 'Order early or miss out' scarcity ran while stock was ample.
Two more violations were stealth marketing: the agency-built sites carried no 'Ad' or 'PR' label, and the 'hair diagnosis expert' on the sales site was the company's own employee, undisclosed as such. On 23 March 2026 Tokyo issued an action order under the Act against Unjustifiable Premiums and Misleading Representations: publicise the violations to consumers, do not repeat them, and train staff on prevention.
Tokyo found seven violations and ordered Pull Charm to publicise them; the proof was manufactured, from composite photos to agency-written testimonials.
Before-and-after photos were composites and user testimonials were written by the ad agency — the proof of efficacy was manufactured, not collected.
Authority was borrowed wholesale: 'state-approved' hair growth and an old Nobel Prize for vitamin research became a 'Nobel-class' claim for one tonic.
The sites were agency-controlled with no ad label, and the 'independent expert' was staff — stealth marketing by design, not by oversight.
Scarcity claims ran while stock was ample: the urgency was scripted, and the script became one of seven violations.
Fabricated proof collapses in a single order: fake before-and-afters, fake reviews, fake scarcity and a fake Nobel sank one tonic. Every testimonial needs a real person.
Pull Charm was ordered to tell consumers that its displays violated the Act against Unjustifiable Premiums and Misleading Representations, to stop similar claims, and to brief its officers and staff on prevention measures. The case was one of the first action orders pairing fabricated-efficacy claims with breaches of Japan's 2023 stealth-marketing notice.
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