テレビや雑誌では「疲れをためないコツ」「リラックス方法」など疲れに関する特集が頻繁に組まれ、書籍でも疲労回復をテーマにしたものが売上げを伸ばしているといいます。それほど多くの人が疲労回復したいと思っているわけです。となれば健康食品でも疲労回復を訴求したくなりますよね。しかしそもそも健康食品で疲労回復(回復)はうたえるのでしょうか?
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。
健康食品で「疲労」「回復」は基本的にNG
薬機法では医薬品的な効能効果の標榜を禁じています。
医薬品的な効能効果とみなされるものに「身体の組織機能の一般的増強、増進を主たる目的とする効能効果」があり、疲労回復(回復)はこれに該当します。
よって健康食品で疲労回復(回復)は原則、標榜できません。
OK表現とNG表現
では薬機法上、どのような表現であれば可能で、どのような表現は認められないのでしょうか。
NG表現
下のケースは基本的に不可となります。
【NG表現】
- 慢性疲労に
- 疲労回復
- 疲れた体に
- 頑張った体の回復に
注目すべきは、直接的に「疲労」「回復」と表示しなくてもNGとなる場合がある点です。
薬機法の違法性は、その広告表現全体が与える印象で判断します。例えば上記「頑張った体の回復に」は誰がどう見ても疲労回復を連想しますよね。そのため認められません。
では「疲労ケア」はどうでしょうか。
「ケア」には「世話・手入れ・管理」などの意味もあるので、必ずしも即不可とはいえません。ただし「疲労」に用いて「疲労ケア」とすると、ほとんどの人は「疲労を回復してくれるんだ」という印象を持ちます。つまり「疲労ケア」は黒に近いグレーです。Life-lighterでは推奨しません。
OK表現
続いて薬機法上セーフとなる表現を見てみましょう。
【OK表現】
- バイタリティーが欲しい
- 元気な体を維持したい人におススメ
- 明日も休めないあなたに
- もうひと踏ん張りのパワーが出ないあなた
- 内側からみなぎる
- スッキリ快調な朝をお届け
- ハツラツとしていたい
- 元気な体を保ちたい
- エネルギッシュなあなたへ導く
【訴求のコツ】
- 状態にフォーカスする
- 状況にフォーカスする
- 抽象的な言葉を使う
- 断定を避ける
訴求のポイントとしてはは「明日も休めないあなた」「スッキリ快調」「元気を保ちたい」など状況や状態にフォーカスすることです。もっとも、「元気を高める」とすると、薬機法違反になる恐れがあるので注意が必要です。保持・現状維持まではOKですが、向上・増進表現はNGとなります。
「内側からみなぎる」「ハツラツ」など抽象的な言葉に置き換える、「導く」など、断定を避けるのもよいでしょう。
その他、単に成分を表記するのも有効です。成分の標榜は広告にあたらないので薬機法の規制対象になりません。 →~~(栄養成分)は健康維持に役立つ成分です。
正しい知識でホワイトな訴求を!
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。
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