「便秘」は誰もが経験する悩みです。だからこそ健康食品でも用いたくなるワードといえます。健康食品(サプリメント)で「便秘」は使えるのでしょうか。
景品表示法務検定アドバンス(消費者庁、公正取引協議会主催)や食品の適正表示推進者(東京都福祉保健局主催)などを所有する専業薬機ライターが解説します。
健康食品(サプリメント)では「便秘」はNG

健康食品(サプリメント)で効能効果として「便秘」の表現を用いると薬機法に抵触します。
健康食品は直接薬機法の対象ではない
そもそも、薬機法(医薬品、医療機器等の品質、有効性及び安全性の確保等に関する法律)はその目的を次のように規定しています。
医薬品、医療機器等の品質、有効性及び安全性の確保等に関する法律は、日本における医薬品、医薬部外品、化粧品、医療機器及び再生医療等製品に関する運用などを定めた法律である(薬機法第一条)
「日本における医薬品、医薬部外品、化粧品、医療機器及び再生医療等製品に関する運用などを定めた」
とあります。
つまり薬機法の規制対象は
- 医薬品
- 医薬部外品
- 化粧品
- 医療機器
です。
健康食品は含まれません。
しかし医薬であるかのごとき表現を用いると薬機法違反
しかしながら、健康食品に効能があるとして販売すると薬機法の規制対象になります。
ここで、そもそも薬機法の規制がどのようになっているのか、確認しておきましょう。
薬機法では医薬品でないものについて医薬品的効果効能を訴求することを禁じています。
問題は、どのような場合に医薬品とみなされるのか、です。いわゆる46通知では医薬品の該当性は以下の観点から判断するとしています。
- 成分本質
- 形状
- 効能効果
- 用法用量
つまり医薬品的な効果効能をうたうと法律上は医薬品の分類になるわけです。しかし健康食品は医薬品ではありません。
したがって便秘が改善・解消するかのような表現(=医薬品的効果効能)は認められないのです。
NG表現とOK表現

では、どのような表現がNGで、どのような表現なら可能なのでしょうか。
NG表現

- 便秘改善
- 長年の宿便が噓のよう
- 便秘が治った
- お通じ
体の具体的な変化を訴求するとすべて違反になります。注意したいのが、「お通じ」も不可である点。「お通じ」は広告ではよく見かける表現ですね。けれども、違反です。摘発リスクがありますので、もし使っていたら今すぐに削除しましょう。
OK表現

擬態語をうまく使ったパターン
- 翌朝ドバババ
- 翌朝スッキリ
- ちょうキレイ!
- スッキリ快チョー!
- びっくりするほどモリモリ
- 恥ずかしいほどドッサリ
- 今日も快調チョーブブリブリ
擬態語をうまく活用することで違反を回避できます。(最後の方は少し汚いですが…)
「状態」をいいかえるパターン
- 朝の重苦しさから解放
- パンパンおなかとさようなら
状態にフォーカスしていいかえるパターンです。状態をいいかえるテクニックは他のNG表現にも応用できますので覚えておくとよいでしょう。
今なら公式LINEでより実践的ないいかえテクニックや、稼ぐための最新薬事ノウハウについて発信しています。
正しい知識で摘発を回避しよう
「便秘は病気ではないので違反に当たらないのでは?」と思われがちですが、薬機法に抵触するといえます。
正しい知識を持つことが大切です。
Life-lighterでは”好かれて売れる訴求”を基本理念に記事制作や法務コンサルティング、セミナー、薬機ライター養成などを行っています。
- さらに詳しく知りたい!
- 扱ってほしいテーマがある!
- この表現はセーフか知りたい!
などでも結構ですので、まずはお気軽にお問い合わせください。
コメント
コメント一覧 (143件)
I truly appreciate this blog article.Really looking forward to read more. Much obliged.
Wow, great blog.Much thanks again. Much obliged.
Hello! I just wanted to ask if you ever have any trouble with hackers? My last blog (wordpress) was hacked and I ended up losing a few months of hard work due to no data backup. Do you have any methods to stop hackers?
diflucan 150 australia
I value the blog.
Thanks for the blog article.Much thanks again. Cool.
My brother recommended I might like this blog. He was entirely right.This post actually made my day. You can not imaginejust how much time I had spent for this information! Thanks!
Hey there just wanted to give you a brief heads up and let you know a few of the images aren’t loading correctly.I’m not sure why but I think its a linking issue.I’ve tried it in two different internet browsers and both show the same results.
No matter if some one searches for his essential thing,so he/she wishes to be available that in detail, so that thing is maintained overhere.
I cannot thank you enough for the blog. Will read on…
I really liked your article.Thanks Again. Really Great.
When someone writes an piece of writing he/she maintainsthe idea of a user in his/her brain that how a user can understand it.Thus that’s why this paragraph is amazing.Thanks!
Hi, I do believe this is a great blog. I stumbledupon it 😉 I am going to revisit once again since I saved as a favorite it. Money and freedom is the greatest way to change, may you be rich and continue to help others.
A motivating discussion is worth comment. There’s no doubt that that you ought to publish more about this subject, it may not be a taboo matter but generally people do not talk about such issues. To the next! Cheers!!
Really informative article.Much thanks again. Will read on…
Really informative blog article.Much thanks again. Really Great.
Thanks for any other great article. Where else may anybodyget that type of information in such a perfect approach of writing?I’ve a presentation next week, and I’m at the search for such info.
Very good post. Want more.
Im thankful for the blog. Really Cool.
Itís hard to come by knowledgeable people in this particular subject, however, you seem like you know what youíre talking about! Thanks
Very good blog post.Really looking forward to read more.
I really loved this piece of content. I’ll be back to read more. Thank you for creating it!
Links Xem Trực Tiếp Soccer Futsal Việt Nam Vs Lebanon Vòng Chủng Loại World Cuplich thi dau laligaNếu cứ đùa như cơ hội vừa tiêu diệt Everton tới 3-1 bên trên sân khách
Greetings! Very helpful advice within this post! It’s the little changes which will make themost significant changes. Thanks a lot for sharing!
cameron court apartments rentberry scam ico 30m$ raised martin luther king apartments
Your style is very unique in comparison to other people I’ve read stuff from. Thank you for posting when you’ve got the opportunity, Guess I’ll just book mark this blog.
I am sure this post has touched all the internet users, its really really good poston building up new blog.
Say, you got a nice post.Really thank you! Much obliged.
I like this blog so much, saved to my bookmarks. «American soldiers must be turned into lambs and eating them is tolerated.» by Muammar Qaddafi.
hydroxychloroquine moa hydroxychloroquine pills
Really appreciate you sharing this post.Really looking forward to read more. Cool.
That is a really good tip especially to those fresh to the blogosphere.Simple but very precise information… Appreciate your sharing this one.A must read post!
I like the valuable info you provide on your articles.I will bookmark your blog and check once more right here regularly.I am moderately certain I will be told a lot of new stuff proper right here!Good luck for the following!
I needed to thank you for this great read!! I definitely loved every bit of it. I have you saved as a favorite to look at new stuff you post…
Thanks on your marvelous posting! I genuinely enjoyed reading it, you are a great author.I will makesure to bookmark your blog and may come backlater on. I want to encourage you to continue your great job,have a nice holiday weekend!
I need to to thank you for this excellent read!! I definitely loved every bit of it.I have got you book-marked to look at new stuffyou post…
Edjhrr – silagra tablets online Eyoswy znkjog
Binance komisyon oranları merak edenler için binance komisyon oranları!Tıklayın ve binance komisyon oranları sayfamıza göz atın. Binance komisyon oranları inceleyin!
What’s up, I log on to your new stuff like every week.Your humoristic style is awesome, keep up the good work!
I do not even know how I ended up here, but I thought this post was great.I don’t know who you are but certainly you’re going toa famous blogger if you are not already 😉 Cheers!
I blog quite often and I genuinely thank you for your information. The article has really peaked my interest. I am going to bookmark your blog and keep checking for new information about once per week. I subscribed to your RSS feed too.
Hello! This post couldn’t be written any better! Reading throughthis post reminds me of my previous room mate!He always kept talking about this. I will forward this post to him.Fairly certain he will have a good read. Many thanks for sharing!
Our business has been mentioned on a blog in a negative way and I am not sure how I can get the anonymous blogger to remove the post.. I’ve emailed her but have had no response. What are my options and what should my next step be?.
I truly appreciate this post. Really Cool.
Enjoyed every bit of your article post.Really thank you! Cool.
I am not real great with English but I come up this very easy to translate.
This is a very good tip especially to those fresh to the blogosphere.Brief but very accurate information… Thank you for sharingthis one. A must read article!
Itís hard to come by experienced people on this topic, but you seem like you know what youíre talking about! Thanks
It’s going to be end of mine day, but before end I am reading this great piece of writing to increase my know-how.
Hi! This post couldn’t be written any better! Reading through this post reminds me of my old room mate! He always kept chatting about this. I will forward this write-up to him. Fairly certain he will have a good read. Many thanks for sharing!
Really appreciate you sharing this post. Great.
Heya i’m for the first time here. I found thisboard and I in finding It really helpful & ithelped me out a lot. I hope to present something again andaid others such as you helped me.
Incredible! This blog looks exactly like my old one!It’s on a totally different topic but it has pretty muchthe same layout and design. Outstanding choice ofcolors!
best online international pharmacies india: all generic meds from india india pharmacies online
Thanks a lot! I enjoy this.best college entrance essay help thesis college essay writing service
Hey, thanks for the article.Really thank you! Great.
Very neat post.Really thank you!
Great blog you have here.. Itís hard to find high quality writing like yours these days. I really appreciate individuals like you! Take care!!
Very good article. I will be going through many of these issues as well..Here is my blog: sky1388 game
Thank you, I have recently been looking for info approximately this topic!!!
how do i order cbd oil from skyline isolation
Repare la PC adherida en Loop Boot en el servicio ASUS BIOS
What’s up, just wanted to say, I loved thisblog post. It was funny. Keep on posting!
These are genuinely fantastic ideas in about blogging. You have touched some fastidious things here. Any way keep up wrinting.
Great, thanks for sharing this blog.Thanks Again. Keep writing.
Im grateful for the blog post.Thanks Again. Keep writing.
Thanks for every other magnificent article. The place else could anybody get that kind of info in such a perfect method of writing? I’ve a presentation next week, and I am at the look for such information.
@ Hope: De acuerdo, TR necesita exponer este polvo.
wonderful issues altogether, you just won a emblem new reader. What may you suggest in regards to your post that you just made some days ago? Any sure?
Hello i am kavin, its my first occasion to commentinganyplace, when i read this article i thought i couldalso make comment due to this sensible paragraph.
brian oneill mens game white jersey nike nfl minnesota vikings road 75 two handle torba picture cases for iphone 8 plus rood rose rugzak mimco iphone x max pouzdro loose bohemian 拧aty sophiescloset
Catherine,Thank you for looking and commenting. Most dictionaries consider “poisonous” and “venomous” as synonyms. Even so, I have updated the blog per your suggestion.
jsEncrypt hello my website is jsEncrypt
purists hello my website is purists
bos868 hello my website is bos868
gorebox hello my website is gorebox
mas 4d hello my website is mas 4d
4d toto hello my website is 4d toto
Adelle hello my website is Adelle
4d v20 hello my website is 4d v20
sona9 hello my website is sona9
Really informative blog article.Thanks Again. Awesome.
Really enjoyed this post.Thanks Again. Cool.
Very informative blog.Much thanks again. Fantastic.
Really enjoyed this blog.Much thanks again. Fantastic.
I value the blog article.Really looking forward to read more. Great.
I want to be able to write entries and add pics. I do not mean something like myspace or facebook or anything like that. I mean an actual blog. .
F*ckin’ amazing things here. I’m very satisfied to see your post. Thank you a lot and i am having a look forward to contact you. Will you kindly drop me a e-mail?
What’s Happening i’m new to this, I stumbled upon this I have found It absolutely useful and it has aided me out loads. I’m hoping to contribute & assist other users like its aided me. Good job.
Your style is unique compared to other people I’ve read stuff from. Many thanks for posting when you have the opportunity, Guess I’ll just bookmark this blog.
used lab equipment dealers[…]Wonderful story, reckoned we could combine a few unrelated information, nonetheless definitely worth taking a search, whoa did 1 find out about Mid East has got much more problerms also […]
ed pills — men’s ed pills vitality ed pills
I value the blog post.Really thank you! Fantastic.
Howdy! I know this is kinda off topic but I was wondering if you knew where I could find a captcha plugin for my comment form?I’m using the same blog platform as yours and I’m having problems finding one?Thanks a lot!
An intriguing discussion is definitely worth comment. I do think that you should publish more about this issue, it might not be a taboo subject but generally folks don’t discuss these issues. To the next! Best wishes.
Muchos Gracias for your blog.Really looking forward to read more. Much obliged.
Thanks for sharing your thoughts on 이번 주에 내 채널에서 마그리나를 보지 말고 viacute_deos do red.Regards
I’m not quite sure where to begin with this, so I’ll just say this is a really good article. I’ve enjoyed reading it and pondering the many points you make.
Very neat article post. Cool.
I really liked your article post.Really looking forward to read more. Cool.
I am so grateful for your article. Fantastic.
A big thank you for your article. Much obliged.
I loved your article.Really thank you! Want more.
Thanks again for the blog post.Much thanks again. Really Cool.
Thanks for the article.Thanks Again.
I need to to thank you for this excellent read!! I certainly enjoyed every bit of it. I have got you saved as a favorite to check out new things you post…
Nicely put, Appreciate it.college board essay professional custom essays online custom writing services
campus apartments spring forest apartments apartments in danbury ct
It worsens bioflavonoid culprits that lead grossly depreciate the joints and. medication for ed dysfunction Hpqtgi cbbywh
I don’t even know the way I stopped up right here, however I believed this submit used to be great. I do not understand who you might be but definitely you’re going to a famous blogger in the event you aren’t already. Cheers!
Very informative article post.Really looking forward to read more. Awesome.
Before you post it, proofread your blog entry, to ensure that it is free from grammatical and typographical errors.
I was suggested this blog by my cousin. I am notsure whether this post is written by him as nobody else know such detailed about my trouble.You are amazing! Thanks!
Your style is really unique in comparison to other folks I’ve read stuff from. Thanks for posting when you’ve got the opportunity, Guess I will just bookmark this blog.
Whoa! This blog looks exactly like my old one!It’s on a entirely different subject but it has pretty much thesame layout and design. Wonderful choice of colors!
BOLI´s Kid Labor Unit critiques the application and,if authorized, sends the validated certificate tothe employer.
Hi friends, pleasant piece of writing and pleasant arguments commented here, I am in fact enjoying by these.
When I initially commented I clicked the -Notify me when new feedback are added- checkbox and now every time a comment is added I get four emails with the same comment. Is there any manner you’ll be able to remove me from that service? Thanks!
Remarkable things here. I’m very glad to look your article.Thank you a lot and I’m taking a look ahead to touch you.Will you please drop me a e-mail?
Enjoyed every bit of your blog article.Thanks Again. Fantastic.
Oh my goodness! an incredible article dude. Thank you However I am experiencing problem with ur rss . Don’t know why Unable to subscribe to it. Is there anyone getting an identical rss problem? Anybody who knows kindly respond. Thnkx
Asking questions are in fact pleasant thing if you are not understanding something fully, but this article presents pleasant understanding even.
Absolutely composed written content, Really enjoyed examining.
Heya i’m for the primary time here. I came across this board and I to findIt really helpful & it helped me out much. I hope to offer one thing again and aid others such as you helped me.
generic ivermectin stromectol ivermectin tablets
A motivating discussion is worth comment. I do believe that you need to write more on this subject, it might not be a taboo subject but typically folks don’t talk about such topics. To the next! Many thanks!!
This article presents clear idea in support of the new visitors ofblogging, that actually how to do running a blog.
I blog often and I really thank you for your content. This great article has truly peaked my interest. I will bookmark your blog and keep checking for new details about once per week. I opted in for your RSS feed too.
Thank you ever so for you article.Thanks Again. Want more.
A big thank you for your article post.Really thank you! Really Cool.
Great, thanks for sharing this blog article.Really looking forward to read more. Keep writing.
wow, awesome blog post.Really looking forward to read more. Really Great.
Very good blog article.Thanks Again. Keep writing.
I value the article.Much thanks again. Will read on…
Appreciate it! Numerous stuff!best online essay writers essaytyper hiring freelance writers
Good way of describing, and nice paragraph to obtain factson the topic of my presentation topic, which i am going to convey in institution of higher education.
Oh, 1000 Followers came after 1 hour ??Loading…
Is anyone here in a position to recommend Leg Avenue? Cheers x
amelia apartments rentberry scam ico 30m$ raised affordable apartments
Muchos Gracias for your blog article. Really Great.
Im grateful for the article post.Really looking forward to read more. Will read on…
Thanks again for the blog post.Really looking forward to read more. Want more.
Really appreciate you sharing this blog post.Much thanks again. Want more.