Section 3(1) of Part 1 of the Guidelines on Promotional Information Activities for Prescription Drugs sets out four minimum requirements that any information-provision activity must satisfy. They are cumulative: a single unmet requirement makes the entire activity non-compliant, regardless of how well the other three are satisfied.
The heart of the four requirements is information completeness and verifiability of evidence. Approved facts, delivered on both efficacy and safety, backed by independently verifiable evidence, with sources disclosed — meeting all four is what makes information usable for prescribing decisions.
01Requirement ① — Information must stay within the approved scope
All information about indications, dosage and administration, and precautions must remain within what has been approved under the Pharmaceuticals and Medical Devices Act. The boundaries of the regulatory approval are the limits of permissible information provision. Even if an indication has been approved in another country, or is supported by published literature, implying or suggesting unapproved uses in an information-provision context is not permitted.
So what: Presenting a foreign-approved indication as "reference information," or using language that suggests a dosing method not covered by the domestic approval, both violate this requirement. The approved scope is strictly the Japanese domestic approval — no geographic exceptions.
So why: Japan's regulatory approval evaluates efficacy, safety, and quality in the context of domestic clinical practice. Circulating unapproved information can prompt uses that have not been through that evaluation, exposing patients to risks the approval process was designed to prevent. Respecting the approved scope is the first line of defence for the safety framework established by regulators.
02Requirement ② — Provide safety information alongside efficacy; do not cherry-pick
When efficacy information is communicated, safety information — including adverse events — must accompany it. In addition, when multiple datasets exist, presenting only the most favourable subset is prohibited as arbitrary selection. This applies equally to choosing between studies and to deciding which outcomes within a study to highlight.
So what: Featuring a response rate prominently while burying serious adverse event rates in fine print, or reporting only the trial with the most statistically significant result when several comparable trials exist, both breach this requirement.
So why: Prescribers need to weigh benefit against risk in the same informational context. A presentation that leaves a strong efficacy impression while relegating safety information to the background distorts that risk-benefit comparison. Banning arbitrary selection preserves the informational symmetry that sound prescribing decisions require.
03Requirement ③ — Scientific and objective evidence; the evidence must be demonstrable
The content of information must be grounded in scientific and objective evidence, and that evidence must be demonstrable on demand. The Guidelines define "scientific evidence" through two pathways:
- Verifiability pathway: Including the underlying data, the evidence is open to objective evaluation and verification by independent third parties.
- Review pathway: The evidence has been through an appropriate third-party assessment (peer review, etc., including regulatory evaluation materials and review reports from the approval process).
"We reviewed this internally" or "our own analysis confirmed it" is not sufficient. The evidence must exist in a form that an independent party can examine and verify.
So what: Citing numbers from a conference abstract alone, presenting trial results that exist only in an internal database, or referencing proprietary analyses whose methodology is undisclosed — none of these meet the "demonstrable evidence" standard. Peer-reviewed original articles and regulatory approval review reports are the practical baseline for evidence in materials.
So why: Companies have an inherent incentive to conduct and cite analyses that favour their products. Requiring third-party-reviewed evidence moves the verification of information quality outside the company's own judgment, and places prescribers in a position where they can independently assess the credibility of what they are being told.
04Requirement ④ — Cite sources; disclose company involvement in external research
All information cited in materials must identify its source. Where a company has provided goods, money, labour, or other support to external research, the specific nature of that support must also be disclosed in the material. Furthermore, data from external research may only be used if that research was conducted in compliance with the Clinical Trials Act and the Ethical Guidelines for Medical and Biological Research Involving Human Subjects.
So what: A reference list at the end of a material may not be enough. When the data come from research that received company funding, the type and scope of that support (goods, money, how much, etc.) must be disclosed specifically. Data from external research that did not comply with applicable ethical guidelines cannot be used regardless of how favourable the results are.
So why: Multiple studies have documented that industry-funded research is more likely to yield positive results. Conflict-of-interest disclosure enables prescribers to calibrate the credibility of evidence for themselves. Barring non-compliant research protects both study participants and the scientific integrity of the data being relied upon.
Requirements ①–④ lock down the obligation to provide information within the approved scope (①), completely (②), with verifiable evidence (③), and transparently (④). A single gap in any of the four makes the information-provision activity non-compliant.