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Detailed Information About the Act against Unjustifiable Premiums and Misleading Representations

Q. What is the Act against Unjustifiable Premiums and Misleading Representations?

Section titled “Q. What is the Act against Unjustifiable Premiums and Misleading Representations?”

A. To protect consumers, unjustifiable premiums and misleading representations about premiums are prohibited

Section titled “A. To protect consumers, unjustifiable premiums and misleading representations about premiums are prohibited”
  • This is the Japanese law officially titled the Act against Unjustifiable Premiums and Misleading Representations.
  • To protect consumers, the Act prohibits unjustifiable premiums and misleading representations about premiums.

Q. What should I be careful about in Pokepay?

Section titled “Q. What should I be careful about in Pokepay?”

A. Make sure the Point Rebate rate does not exceed the regulations

Section titled “A. Make sure the Point Rebate rate does not exceed the regulations”
  • If the Point Rebate rate is too high, it may be subject to regulations under the Act against Unjustifiable Premiums and Misleading Representations.
  • As a general rule, the following regulations apply.

🎁 For transactions of JPY 1,000 or more: Make sure the Point Rebate rate does not exceed 20%.


For transactions of less than JPY 1,000: Make sure the rebate amount does not exceed JPY 200.

ℹ️ If you are unsure, use the following setting.

  • Set Point Rewards to no more than 20% of the transaction amount.

A. Be careful when providing Points through a lottery campaign

Section titled “A. Be careful when providing Points through a lottery campaign”
  • There are points to be careful about when running an in-store lottery campaign using Pokepay’s Point Reward feature.

🎁 For transactions of JPY 5,000 or more, do not provide Points exceeding JPY 100,000 worth.


✅ Spend JPY 5,000 and receive JPY 10,000 worth of Points through a lottery

❌ Spend JPY 5,000 and receive JPY 1,000,000 worth of Points through a lottery

🧧 For transactions of less than JPY 5,000, do not provide Points exceeding 20 times the transaction amount.


✅ Spend JPY 1,000 and receive JPY 20,000 worth of Points through a lottery

❌ Spend JPY 1,000 and receive JPY 500,000 worth of Points through a lottery

In either case, the total amount of all provided Points must not exceed 2% of the expected total sales amount related to the campaign.

For more detailed information, check the websites of the Consumer Affairs Agency or other administrative agencies.

Consumer Affairs Agency - Act against Unjustifiable Premiums and Misleading Representations

caa.go.jp


  • Many people may associate the word “premium” with prizes at a festival game. Under the law, however, the scope is somewhat broader.
  • In legal terms, providing goods, money, or other benefits with economic value in connection with transactions for products or services, as a means of inducing customer behavior, is called a “premium.”*1
  • In Pokepay, if Points are provided in response to a transaction, those Points are considered likely to fall under premiums.

📝 Memo: If all of the following three points are not satisfied, it is not treated as a premium.

  • As a means of inducing customer behavior…
  • In connection with transactions for products or services…
  • Providing goods, money, or other benefits with economic value

For example, even if a handshake-event ticket is included as a bonus with the purchase of a music CD, it is unlikely to be considered to have economic value under item 3, so it would not be treated as a premium.

*1 Article 2, paragraph 3 of the Act against Unjustifiable Premiums and Misleading Representations defines this as an economic benefit provided by a business operator to another party in connection with a transaction as a means of inducing customers, and designated by the Prime Minister.

Q. How far does “in connection with a transaction” extend?

Section titled “Q. How far does “in connection with a transaction” extend?”

A. For example, “receive a gift just for visiting” is also connected with a transaction

Section titled “A. For example, “receive a gift just for visiting” is also connected with a transaction”
  • Providing premiums only on the condition of a transaction, such as Point Rewards for purchases, is not the only case covered by the Act against Unjustifiable Premiums and Misleading Representations.
  • Premiums connected with transactions, such as “receive a gift just for visiting,” are also subject to the Act against Unjustifiable Premiums and Misleading Representations.
  • Because the Act may apply more broadly, contact the Consumer Affairs Agency or another administrative desk for details.

Consumer Affairs Agency - Website

caa.go.jp

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