Japan targets deceptive online subscription traps with tougher enforcement

A rising wave of hidden subscriptions hits Japanese shoppers

Japan’s consumer watchdog has moved aggressively against misleading online subscription sales after a spate of complaints from shoppers who believed they were making a one time purchase but were instead enrolled in a repeating plan. The Consumer Affairs Agency suspended the operations of Tokyo based retailer BIZM for six months after finding that sales of its Skin Venus Premium Repair Cream concealed a subscription and included a hefty cancellation fee. Regulators said the offer violated the Act on Specified Commercial Transactions, and they also flagged unproven claims about the product’s ability to remove skin spots in a week.

The case spotlighted how online storefronts can obscure the most important information at the moment a buyer clicks pay. Marketing pages and banners trumpeted low trial prices and easy ordering, while the final checkout page failed to say plainly that the purchase would trigger repeat shipments and repeat charges. Critical terms sat far below the fold inside dense rules, out of sight of many customers.

Consumer affairs centers across the country have registered a sharp rise in calls about these traps. Consultations related to online subscriptions climbed from roughly 58,000 cases in fiscal 2021 to 89,000 in fiscal 2024. Cosmetics and health foods dominate the complaints. To match the scale of the problem, the Consumer Affairs Agency has stepped up enforcement, taking administrative action in 28 cases in fiscal 2024, compared with seven the prior year. The message to online sellers is that vague screens, buried fine print, and inflated product claims are no longer tolerated.

How the Skin Venus case worked

The Skin Venus offer enticed shoppers with a steep discount, then tied that discount to continuing purchases. The product page listed a reference price of 22,110 yen, while a checkout coupon appeared to drop the first payment to 2,420 yen. Buyers who tried to stop after receiving the first bottle discovered a cancellation fee of 11,055 yen, roughly the price cited for one bottle, unless they continued. Regulators said the final confirmation screen did not clearly indicate any subscription, and the real conditions were tucked away at the bottom of the terms of use.

Promotional copy amplified the sense of urgency and simplicity. It promised low cost access and implied that there was no ongoing obligation. It also touted benefits that the company could not substantiate.

Promotional language on the site included:

“For just 1,980 yen, you can try premium spot care.”

“One time only. No need to cancel.”

“Removes skin spots in seven days.”

Regulators said these phrases misrepresented both the nature of the purchase and the product’s effects. When buyers clicked through, crucial information about repeat shipments and cancellation penalties was effectively hidden. That combination of persuasive sales copy and poorly disclosed obligations is the hallmark of a subscription trap.

What Japanese law requires online sellers to disclose

The Act on Specified Commercial Transactions (often called Tokutei Shotorihiki Ho) requires clear, prominent disclosure of key terms in mail order transactions, including online sales. Sellers must show the total cost, the recurring nature of a plan if there is one, and the conditions for cancellation before the buyer completes the order. Hiding recurring charges in a remote link or burying them in long terms of use does not meet the standard of a clear display. Authorities can issue corrective orders and, in severe cases, suspend business operations.

Many shoppers assume there is a “cooling off” period for any unwanted purchase. That protection generally applies to door to door and telemarketing contracts, not to ordinary online purchases. Online buyers often have no automatic right to withdraw once a transaction is completed unless the advertisement or contract itself is illegal or misleading. This is why the foundation of consumer protection for online shopping is accurate, conspicuous disclosure at the point of sale.

Japan also polices marketing itself. The Act against Unjustifiable Premiums and Misleading Representations prohibits exaggerated or deceptive claims. If a product is said to remove skin spots in seven days, there must be solid evidence to back that up. Without evidence, a seller can be ordered to correct the representation and, in some cases, face surcharges or other penalties. The Skin Venus action involved both improper subscription practices and unproven performance claims, a combination that regulators have warned they will target.

Why these tactics took off during the online shopping boom

The pandemic years accelerated a major shift to online shopping in Japan. Cosmetics and health foods, the two categories most often cited in consumer complaints, are a natural fit for subscription models. They are consumable, margins can be high, and marketers prefer predictable repeat revenue. A deep discount on the first delivery creates a sense of value that nudges shoppers to complete the checkout, especially when the recurring nature of the deal is not front and center.

Another factor is the rise of performance based advertising and affiliate networks. Sellers pay partners when a sale occurs, so there is intense pressure to maximize conversion with copy that promises quick results and a price that looks too good to ignore. Some sites use manipulative design tricks to keep customers from noticing ongoing obligations. These include small or low contrast text disclosing monthly charges, preselected options for repeat shipments, or checkout pages that emphasize countdown timers and coupons while important terms sit far below.

The psychology is simple. A limited time price anchor and a bold claim can eclipse the practical question of how much the customer will ultimately pay. The result is more complaints and closer scrutiny by regulators, who view these interfaces as deceptive when they obscure a recurring charge.

Enforcement accelerates with tougher penalties

Inquiry numbers tell a clear story. The National Consumer Affairs Center recorded about 58,000 inquiries about online subscriptions in fiscal 2021, rising to 89,000 in fiscal 2024. Facing this surge, the Consumer Affairs Agency created a dedicated team in 2023 to track exaggerated online advertising and malicious subscriptions. The agency reported 28 administrative actions in fiscal 2024, up from seven a year earlier. That includes orders to correct displays, surcharges in appropriate cases, and business suspensions for serious or repeated violations.

Penalties can be severe. A business suspension order cuts off a company’s ability to sell for a defined period, in BIZM’s case six months. Regulators can also require clear corrective displays and notify the public of the violation. If ads make health or cosmetic claims, a separate legal framework governs the substantiation of those claims. Over time, repeated violations raise the likelihood of stricter sanctions.

Complaints cluster in categories that rely on promises of visible change or wellness. Skin care, whitening creams, supplements, and diet products sit at the center of the problem. A growing marketplace will draw even more sellers. New social commerce channels are entering Japan, and live shopping features will make it easier for small brands to pitch trial offers inside streaming video. That expansion increases the importance of clear, standardized disclosures and easy cancellation processes.

Consumers who feel misled can contact their local consumer affairs center and their card issuer. In cases of deceptive displays, they may be able to reverse charges or negotiate refunds. Keeping screenshots of the checkout flow, including any coupon references and the terms displayed at the time of purchase, can support a complaint.

Protect yourself when offers promise easy trials

Trial offers and first time discounts can be legitimate. The problem starts when recurring charges are hidden or when the seller makes claims that are not backed by evidence. A few habits can reduce the risk of an unwelcome subscription.

• Scroll to the bottom of every checkout page and look for the words subscription, regular delivery, automatic shipment, or monthly plan.
• Check for any mention of a cancellation fee, minimum number of shipments, or a requirement to call or send a form to cancel.
• Read the final confirmation screen carefully. If the purchase is truly one time, it should say one time purchase or single delivery clearly.
• Beware of steep first order discounts that drop a price from a high listed amount to a very low payment. That gap often signals an ongoing plan.
• Be cautious with miracle claims. If a product promises dramatic results in a few days, look for independent testing or evidence.
• Screenshot the key screens, including the total price and the terms shown at checkout. Save confirmation emails.
• Look for the seller’s legal name, address, and contact method. Legitimate sites list this information prominently.
• Use a credit card rather than a bank transfer. It is easier to challenge a charge if there is a dispute.
• Search the product name with the word complaint or cancellation to see if others have faced similar issues.
• If you feel misled, contact your local consumer affairs center promptly and document what you saw.

Clear displays help both sides. Honest sellers benefit when buyers know exactly what they are agreeing to, and shoppers gain confidence in online deals that spell out the terms without tricks.

A wider digital cleanup across Japan

The subscription crackdown is part of a broader tightening of rules across the country’s digital economy. Authorities and industry groups have poured resources into protecting creative works and consumers online. A new government strategy for entertainment and creative industries includes a drive to curb counterfeit anime goods sold through overseas platforms, with cooperation from the Content Overseas Distribution Association. The plan sets a long term goal to expand content exports by 2033, and it pairs growth measures with stronger enforcement against fakes that mislead fans and damage brands.

Publishers and agencies are also turning to technology to combat piracy. An initiative backed by public funds is testing artificial intelligence that can detect infringing images and text and flag thousands of suspect sites for action. Police have taken aim at leakers and sellers who profit from illicit content, including arrests linked to the sale of AI generated obscene posters through online auction sites.

Japan’s stance on online gambling shows a similar pattern. Domestic online casino operations remain prohibited, yet millions of residents can access foreign sites. Police have intensified investigations, including the use of cryptocurrency tracking tools in recent arrests. Industry voices argue over whether tighter enforcement or regulated channels would better protect players, but each step signals continued attention to online risk.

Even public media is changing how access is controlled. NHK has begun linking its digital news service to subscriber credentials and assembled a team dedicated to fee enforcement. That shift reflects a willingness to use access gates and verification to curb free riding in a subscription model.

Tourism policy is also moving toward tighter rules. Plans for an electronic travel authority for visa free visitors and new procedures for tax refunds aim to reduce abuse and verify eligibility. The tax change, scheduled for late 2026, will require visitors to pay at the register and claim refunds later, which reduces the chance of improper duty free sales.

Global context and lessons for platforms

Japan is not acting in isolation. In Europe, the Digital Markets Act targets very large platforms with tough obligations and fines of up to 10 percent of global turnover for serious violations. While the DMA focuses on competition and gatekeeper behavior, it is part of a package of digital laws that raise the bar on transparency and consumer protection online. The signal to global platforms is that opaque designs and hard to cancel services will face resistance.

Across Asia, governments are pursuing their own priorities. China’s market regulator has levied penalties on tech companies that failed to report acquisitions as required, citing concerns about concentration and consumer harm. The message is that unchecked control of distribution channels can attract scrutiny. In India, regulators have tightened standards for networked hardware and are testing products for security risks. These moves reflect a common thread, authorities want more visibility into the technology layer behind online services.

International cooperation is gaining importance in areas like digital black markets. Cross border investigations, information sharing between law enforcement, and partnerships with payment providers and exchanges are now common tactics. The lesson for online sellers is straightforward. Transparency in pricing and clear cancellation paths are not only good practice, they lower legal risk as rules align across markets.

Live shopping systems and short video storefronts are rolling into Japan’s retail scene. These channels can thrive if they present terms in clear language during the stream and at checkout, and if they keep cancellation as simple as signing up. Platforms that invest in plain disclosures and evidence based marketing will be better placed as enforcement continues to rise.

At a Glance

• Japan suspended online retailer BIZM for six months for concealing a subscription and making unproven claims about a beauty cream.
• Buyers were shown a low first payment but faced a cancellation fee of 11,055 yen if they stopped after the first bottle.
• Online subscription inquiries rose from about 58,000 in fiscal 2021 to 89,000 in fiscal 2024, with cosmetics and health foods leading cases.
• The Consumer Affairs Agency took action in 28 cases in fiscal 2024, up from seven the year before, and formed a team in 2023 to tackle deceptive online ads.
• The Act on Specified Commercial Transactions requires clear disclosure of recurring charges before purchase and allows penalties for violations.
• Cooling off rules generally do not apply to ordinary online purchases, which makes conspicuous disclosure at checkout critical.
• Authorities are also cracking down on piracy, counterfeit anime goods, illegal online gambling, and other digital abuses.
• Global regulators are pressing for transparency, with Europe’s new laws and China’s penalties signaling tougher oversight of digital markets.
• Consumers can reduce risk by looking for recurring terms on the final screen, checking cancellation rules, and documenting what they saw.
• Platforms and sellers should make subscriptions explicit, keep cancellation easy, and back product claims with evidence to avoid sanctions.