Promotional interactions are two-way. A medical representative visits a healthcare professional (HCP), provides product information, and the HCP receives it. Most of the GL disciplines the sender's side—the company. Section 4.7 turns to the receiver's side and articulates what HCPs are expected to bring to the exchange.
Article 1-5 of the Pharmaceutical and Medical Device Act (PMD Act) requires HCPs to "endeavor to deepen their knowledge and understanding of the efficacy and safety of drugs and other matters related to their proper use." Section 4.7 draws on this legal foundation to extend the GL's reach: HCPs are expected to understand what appropriate company conduct looks like and to evaluate what they receive against that standard.
01Two dimensions of what is expected
Section 4.7 does not ask HCPs to be passive. It frames two connected expectations.
Dimension 1 — Understanding: HCPs should understand what constitutes appropriate sales information activity by companies under the GL. This means knowing that materials should have passed a review process, that an approved supervisory committee should stand behind what is presented, and that certain conduct is prohibited.
Dimension 2 — Evaluation: HCPs should maintain a posture of objectively assessing whether the activities they receive from companies are being conducted in accordance with the GL. Vague discomfort is not enough; the GL itself is the standard against which to measure.
So what: HCPs are expected to know the GL exists, understand its content, and use it as a reference when evaluating whether what they receive is appropriate. "That is the company's problem" is not a satisfactory stance.
So why: Promotional interactions only produce compliant outcomes if the receiving party can recognize when something is wrong and push back. An HCP who accepts whatever is offered—regardless of whether it meets GL standards—removes the last layer of protection against internal control failures on the company side.
02The weight of a "best-efforts" obligation
Section 4.7 uses the language of endeavor—"strive to," not "shall." This is structurally different from the hard obligations the GL imposes on companies (committee establishment, pre-review of materials). No administrative sanction flows directly from failing to meet this standard.
That said, the obligation is not trivial. Grounded in PMD Act Article 1-5, it confirms that HCPs are participants in the shared goal of appropriate drug use—not merely consumers of information. Reading the GL as a whole, Section 4.7 rejects a model in which companies bear all accountability and HCPs bear none.
So what: The absence of a direct sanction does not make the obligation optional. An HCP who makes no effort to understand or evaluate company conduct effectively creates a permissive environment in which non-compliant activity goes unchallenged.
So why: Drug promotion directly affects patient safety through the treatment decisions HCPs make. In a domain with significant information asymmetry, an informed and evaluative HCP is a structural check on corporate conduct—one that operates independently of administrative enforcement.
03Knowing the GL as a prerequisite
Evaluating company conduct against the GL requires knowing what the GL says. Companies have obligations to train their representatives, but HCPs are also expected to proactively access the GL and develop their own view of what appropriate conduct looks like.
The Ministry of Health, Labour and Welfare publishes the GL, and relevant professional associations and industry bodies distribute guidance on it. "I did not know the GL existed" does not excuse the endeavor obligation.
So what: The GL is publicly available and designed to be accessible to HCPs. Reading it, understanding it, and maintaining the ability to evaluate company activities against it is the operational content of what Section 4.7 asks for.
So why: Compliance that depends on ignorance is not compliance—it is accident. When HCPs understand the rules and consciously evaluate what they receive, non-compliant conduct faces a knowledgeable audience. That awareness is a deterrent that administrative inspection alone cannot replicate at scale.
Section 4.7 reflects a design choice: the GL's effectiveness does not end at the company's internal controls. When HCPs know the GL, understand what appropriate conduct looks like, and evaluate what they receive against that standard, they form a final barrier against promotional excess. The "endeavor" framing understates the real significance—a GL-literate HCP community is a structural deterrent, not a courtesy.