Consumer Affairs Agency Issues Premiums and Representations Act Order Over Funeral Service TV Commercials (18 September 2026)
Consumer Issues3 min readPublic-source summary

Consumer Affairs Agency Issues Premiums and Representations Act Order Over Funeral Service TV Commercials (18 September 2026)

This article compiles what Japanese government bodies have published, together with the statutory text. Links to the primary sources are included. For a specific matter, pleasecontact us.

Key Takeaways

  • ✓On 18 September 2026 the Consumer Affairs Agency announced an order against 株式会社金宝堂 under Article 7(1) of the Premiums and Representations Act
  • ✓The order concerns TV commercials for a family funeral service using private halls, supplied under the trade name 小さな森の家
  • ✓The Agency found the commercials, including the text "family funeral from 104,500 yen (tax incl.)", represented that the service was available at a minimum price of 104,500 yen
  • ✓According to the Agency, in all but a few cases the service in fact cost 308,000 yen or more
  • ✓The Agency found the representation fell under Article 5(ii) (misleading representation as to advantageous terms)
  • ✓The order requires notice to consumers, preventive measures communicated to employees, no repetition of similar representations, and a report to the Commissioner
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On 18 September 2026 Japan's Consumer Affairs Agency (CAA) announced that it had issued an order under Article 7(1) of the Act against Unjustifiable Premiums and Misleading Representations (the Premiums and Representations Act) against 株式会社金宝堂, concerning representations for a funeral service supplied by the company. The CAA found that the conduct fell under Article 5(ii) of the Act (misleading representation as to advantageous terms).

This page sets out what the CAA published, together with the statutory wording.

Overview

ItemDetail
Date of announcement and order18 September 2026
Issuing authorityConsumer Affairs Agency
Addressee株式会社金宝堂 (Shibuya, Tokyo)
Legal basisArticle 7(1), Premiums and Representations Act
Provision found applicableArticle 5(ii)
Service concernedFamily funeral service using private halls, supplied under the trade name 小さな森の家
MediumTV commercials broadcast on terrestrial television

The representations

According to the published material, the commercials broadcast from 1 to 24 March 2025, for example, included:

  • On-screen text reading "one family per day, private hall"
  • The voice-over "so many halls to choose from" with matching on-screen text
  • The voice-over "great-value plans from this price" with on-screen text reading "family funeral from 104,500 yen (tax incl.)"

The CAA stated that these representations gave the impression that the service was available at a minimum price of 104,500 yen.

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Periods of representation

Period
1 to 24 March 2025
26 March to 18 April 2025
21 April 2025
1 to 22 May 2025
26 May 2025
28 to 31 May 2025

The facts found

According to the published material, in all but a few cases the service in fact cost 308,000 yen or more.

What the order requires

  • Notify consumers that the representations were misleading as to advantageous terms and violated the Act (the method requires prior approval of the Commissioner of the CAA)
  • Take measures to prevent recurrence and communicate them to employees
  • Not make similar representations in future
  • Report promptly in writing to the Commissioner on the notice given and measures taken

Statutory wording

Article 5 of the Act provides that a business must not, in connection with transactions for goods or services it supplies, make any representation falling under any of its items. Item (ii) covers representations that cause general consumers to mistakenly believe that the price or other terms of transaction are substantially more advantageous to the counterparty than the actual terms, or than those of competitors, and that are found likely to induce customers unjustly and to impede voluntary and rational choice by general consumers.

Article 7(1) provides that where there is conduct violating Article 4 or Article 5, the Prime Minister may order the business to cease the conduct, to take the measures necessary to prevent its recurrence, or to make a public notice or take other necessary measures relating to their implementation.

Sources

  • Consumer Affairs Agency, announcement of 18 September 2026: https://www.caa.go.jp/notice/entry/047522/
  • Published material (PDF): https://www.caa.go.jp/notice/assets/representation_cms209_260918_01.pdf
  • Premiums and Representations Act (e-Gov): https://laws.e-gov.go.jp/law/337AC0000000134

This page is compiled from material published by government agencies and from statutory text. Please consult a lawyer where a decision is needed on specific advertising.

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This article provides general legal information and does not constitute legal advice. For specific legal issues, please consult with a qualified attorney.

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