"STRONG." "The ultimate." "Superior." "The only drug." When these words appear in product presentations, what evidence actually supports them? Since fiscal year 2019, Japan's Ministry of Health, Labour and Welfare has compiled and published annual reports on the pharmaceutical sales information monitoring program, aggregating suspected-violation reports submitted by healthcare institutions. Across seven years of reports, cases involving exaggerated expressions appear repeatedly. Reworking a translation, swapping the order of endpoints, calling one institution's protocol a "guideline" — the tactics vary, but every case reduces to the same question: "Is there actually evidence to say that?"

So What / So Why — The Core Problem with This Category

"Exaggerated expression" refers to the use of words, visuals, or logic that makes a drug's efficacy, safety, or competitive standing appear greater than the underlying data support. Blatant cases of the textbook variety are rare. Most appear as an accumulation of seemingly minor decisions — a choice of translation, the order in which endpoints are presented, the selection of a headline phrase.

So what (what is actually at stake) — Healthcare professionals base prescribing decisions on the information they receive. A single word like "STRONG," used without head-to-head trial data, can cause a physician to assume superiority over other agents, distorting prescribing choices. If the phrase "the only drug" rests solely on a secondary endpoint, the prescribing physician hands that drug to a patient without knowing the limits of the primary endpoint.

So why (why this is serious) — Drug efficacy and safety are assessed through pre-specified trials with pre-specified endpoints. Exaggerated expression rewrites that framework after the fact. Physicians make prescribing judgments knowing the trial hierarchy (primary endpoints outrank secondary ones), whether statistical significance was achieved, and whether a head-to-head comparison exists. Exaggerated expression dismantles those assumptions. Patients have no way to verify trial limitations on their own; if an error enters at the upstream point of prescribing, the harm reaches the patient directly.

Beyond individual cases, exaggerated claims distort the market as a whole. When a drug wins adoption on the basis of unsupported superiority claims, a more appropriate alternative stays on the shelf. The structural risk of misallocating medical resources lies just beneath what appears to be a question of word choice.

What / Where / Why / How — Which Guideline Requirements Were Violated

What (the nature of the violation)
Cases fall into five broad types: ① use of unsupported catchphrases ("STRONG," "the ultimate," "superior"); ② converting a product name's etymological meaning or connotation into a promotional claim; ③ presenting endpoints or analyses outside the trial design as evidence of efficacy; ④ inflating safety claims through logical leaps; ⑤ elevating a single institution's clinical protocol or an individual expert's opinion to the status of a "guideline" or "expert-confirmed" finding. In fiscal year 2025, one reported case involved a brochure stating that the product was "the only drug shown to improve survival" when the supporting data came exclusively from a secondary endpoint.

Where (which channels and settings)
Violations have been confirmed across virtually every information channel: journal advertisements, product brochures, promotional flyers, MR verbal explanations during pharmacy department hearings, online group meetings, and presentation slides. Patient-facing materials are included as well (a chart-based case involving an antipyretic analgesic anti-inflammatory agent), meaning the distortion sometimes reaches patients without passing through a healthcare professional.

Why (what drives those who create these materials)
Four psychological drivers explain the pattern. First, motivated reasoning (conclusion first, data second): a firm conviction that "this drug is superior" leads to selecting supporting language after the fact. Second, local rationalization (it's just one slide): the color choice in a single figure or the translation of a single term becomes exaggerated, yet the creator defends the overall material as accurate. Third, the sin of omission: the "choice not to mention" a primary endpoint that failed to reach significance is itself a form of exaggeration. Fourth, responsibility transfer: citing "Professor X also says so" substitutes authority for evidence, outsourcing the claim to a name rather than to data.

How (specific provisions violated)
The MHLW's Guidelines on Sales Information Activities for Prescription Drugs (2019) explicitly require that companies "not engage in information activities that involve false or exaggerated expressions, expressions likely to cause misunderstanding, or activities that otherwise conflict with laws and regulations concerning advertising" (Section 3-2(1)). The same guidelines prohibit "selectively presenting only favorable information regarding efficacy and safety" as a scientific basis for information provided. Article 66 of the Pharmaceuticals and Medical Devices Act prohibits "advertising, describing, or disseminating false or exaggerated articles" concerning a drug's name, indications, or effects. The Standards for Appropriate Pharmaceutical Advertising (notification from the Director of the Office of Pharmaceutical Safety, MHLW) likewise state that "superlative expressions or expressions equivalent thereto shall not be used regarding the efficacy, effects, and safety of drugs." The Japan Pharmaceutical Manufacturers Association Code of Practice establishes self-regulatory rules to the same effect.

Cases — Every Instance on Record

Fiscal Year 2019 (Heisei 31)

Channel / Product area: Product brochure / Oncology (anticancer agent)
What was done: A comparison graph of VEGFR inhibitory activity against a comparator drug translated the original paper's vertical-axis labels "Less potent" and "More potent" as "軽微な阻害作用" (mild inhibitory effect) and "著明な阻害作用" (marked inhibitory effect). The visual framing gave the impression that only the promoted product possessed "marked" inhibitory activity.
The violation: Replacing the original authors' neutral language with translations that carry a strong evaluative gradient exaggerated the product's competitive advantage. A textbook case of translation choice as exaggeration.
Source quotation: "The translation of expressions from the original paper was inaccurate."

Channel / Product area: Journal advertisement / Anti-allergy agent
What was done: The advertisement used "STRONG" as its headline catchphrase. All clinical trials for the approved indication were either single-arm or placebo-controlled; no evidence existed that the product was more effective than any comparator.
The violation: Without head-to-head trial data, the word "STRONG" created a false impression of superiority over other agents.
Source quotation: "The expression 'STRONG' was used without any evidence that efficacy was superior to other agents."

Channel / Product area: Verbal explanation / pharmacy hearing materials / Antibacterial agent
What was done: During a pharmacy department hearing, the company representative highlighted the product name's etymology — which included a word meaning "outstanding" — and emphasized that the drug possessed "outstanding efficacy." The clinical trial was a non-inferiority study against a comparator.
The violation: The product name's etymology was repurposed as a promotional claim, describing a non-inferiority drug as having "outstanding efficacy."
Source quotation: "The product name's etymology, for which sufficient evidence was lacking, was used for promotional purposes."

Channel / Product area: Product brochure / Analgesic
What was done: The brochure sequentially presented data linking NSAIDs to blood pressure elevation, data showing no blood pressure change with the promoted product, and a general statement that hypertension is a risk factor for chronic kidney disease. The combined effect created the impression that the product has less adverse impact on renal function — even though the product is contraindicated in patients with severe renal impairment.
The violation: A logical chain connecting blood pressure to renal function was used to inflate safety claims. A drug with a contraindication in renal impairment was made to appear safe.
Source quotation: "Safety was exaggerated on the basis of a leap in logic."

Channel / Product area: Product brochure / Antithrombotic agent
What was done: The brochure included a "DIC treatment algorithm" listing the promoted product alongside a comparator. The cited paper, however, described a single institution's clinical protocol covering only the comparator; the promoted product was not mentioned in the original paper. The source citation was also inaccurate.
The violation: One hospital's internal protocol was presented as though it were a guideline supporting use of the promoted product, inflating the evidence base for that product.
Source quotation: "A single institution's clinical protocol was presented in an exaggerated manner, as if it were a treatment guideline."

Channel / Product area: Promotional flyer / Glaucoma and ocular hypertension treatment
What was done: A flyer for this generic product carried the catchphrase "superior intraocular pressure-lowering effect." No supporting evidence was cited.
The violation: A generic product with no proprietary efficacy data used the word "superior" without any evidentiary basis.
Source quotation: "The word 'superior' was used without basis to exaggerate the drug's effect."

Channel / Product area: Presentation slides / Hemophilia treatment
What was done: A product presentation introduced clinical trial results under the heading "outcomes were favorable." When asked to define the standard for "favorable" — the trial had no control arm — the representative replied that there was no defined benchmark and that it was "based on the judgment of specialist physicians."
The violation: Results from an uncontrolled single-arm trial were described as "favorable," and an individual physician's opinion was used as the evidentiary basis for efficacy.
Source quotation: "Single-arm trial results were presented as 'favorable' on the basis of an individual physician's opinion."

Fiscal Year 2020 (Reiwa 2)

Channel / Product area: Product brochure and verbal explanation / Analgesic
What was done: An MR acknowledged that "no direct comparative trial exists," then used the difference in dissociation half-lives from two subunit binding sites to assert definitively that the promoted product causes fewer adverse effects than a comparator. The regulatory review report stated that adverse event rates were comparable between the two drugs.
The violation: In the absence of direct comparative data, a theoretical mechanism-of-action argument was used to make a definitive claim of fewer adverse effects.
Source quotation: "An explanation asserting fewer adverse effects than other agents was given solely on the basis of a mechanistic rationale."

Channel / Product area: Slides and verbal explanation / Enteral nutrition product
What was done: At an in-hospital information session, a slide titled "suitable for orally-fed patients" was presented as the first listed product feature and explained actively. The clinical trial had been conducted exclusively in tube-fed patients; no data existed for oral administration.
The violation: A route of administration with no supporting trial data was highlighted as a product feature.
Source quotation: "A route of administration for which no trial data existed was actively presented and explained."

Channel / Product area: Verbal explanation / Antibacterial agent
What was done: An MR showed a graph comparing antibacterial activity against multiple bacterial species and stated verbally that "the product demonstrated higher antibacterial activity than the comparator against every bacterial species tested." The graph visibly showed at least one species for which the comparator had higher activity.
The violation: A verbal claim of superiority across all species directly contradicted the data shown in the accompanying graph.
Source quotation: "The exaggerated expression that the product 'demonstrated higher antibacterial activity than the comparator against every bacterial species' was used."

Channel / Product area: Pharmacy hearing materials / Antibacterial agent
What was done: During a pharmacy department hearing, a medical science liaison described the product as "the ultimate [drug class]" on the basis of its mechanism of action and clinical data.
The violation: A superlative expression — "the ultimate" — was used without objective supporting evidence.
Source quotation: "A medical science liaison from the pharmaceutical company used the exaggerated expression 'the ultimate' in the explanation."

Fiscal Year 2021 (Reiwa 3)

Channel / Product area: Online meeting and verbal explanation / Antipsychotic
What was done: Despite a footnote in the explanatory materials stating that the data did "not represent a comparison between the two treatment groups," the representative used the placebo-superiority results from each product's separate trial to claim that the promoted product and a comparator were equivalent in efficacy.
The violation: Data from trials not designed for head-to-head comparison were used to assert equivalence.
Source quotation: "An explanation was given that ignored the caveat stating the data did 'not represent a comparison between the two treatment groups.'"

Channel / Product area: In-person verbal explanation / Oncology (anticancer agent)
What was done: The trial protocol pre-specified central review as the primary assessment. At a product information session, the representative explained that "while statistical significance was not achieved by central review, significance was achieved by investigator assessment" — presenting the non-pre-specified assessment alongside the primary result.
The violation: The absence of significance on the pre-specified primary assessment (central review) was downplayed, and the investigator assessment was used to overstate efficacy.
Source quotation: "While statistical significance was not achieved by central review, significance was achieved by investigator assessment."

Fiscal Year 2022 (Reiwa 4)

Channel / Product area: Verbal explanation and presentation slides / Diabetes treatment
What was done: When asked for subgroup analysis data in the Japanese population, the MR stated that "a clear difference was seen even in Japanese patients" — despite the analysis not reaching statistical significance. When the absence of significance was pointed out, the MR responded that "Professor X has stated that sufficient efficacy can be expected, so there is no problem," citing expert opinion to sidestep the question.
The violation: A non-significant result was described as "showing a clear difference"; when challenged, the representative substituted authority for evidence rather than addressing the statistical finding.
Source quotation: "A clear difference was seen even in Japanese patients."

Fiscal Year 2023 (Reiwa 5)

Channel / Product area: Patient-facing materials / Antipyretic analgesic anti-inflammatory agent
What was done: A patient-facing document included a diagram implying that this systemically acting transdermal patch was stronger and broader in effect than oral drugs and locally acting patches. The promoted product was illustrated in a deep color reaching the extremities throughout the body; the oral drug was shown in a lighter color covering a narrower area. Only the promoted product's label used the word "systemic" in notably larger text than the comparators.
The violation: Color intensity, size, and coverage area — visual tools rather than words — created an exaggerated impression that the product's effects were both stronger and more extensive, leading patients to misunderstand the drug's comparative profile.
Source quotation: "A diagram was included that gave the impression that the effect was strong and covered a wide area."

Fiscal Year 2024 (Reiwa 6)

The fiscal year 2024 report recorded zero cases in the category of exaggerated expressions used to explain data. This may reflect the impact of corrective measures taken by companies in response to prior-year cases. However, multiple cases were still reported in other categories — including potentially misleading factual claims and disparagement of competing products — confirming that the quality management of information provision remains an ongoing challenge.

Fiscal Year 2025 (Reiwa 7)

Channel / Product area: Online group meeting and brochure / Diabetes treatment
What was done: Regarding an international phase III trial, an MR explained verbally that "this product is the only treatment shown to improve survival," and the same wording appeared in the brochure. The "survival improvement" data, however, came from time to all-cause death, which was a secondary endpoint in the trial.
The violation: A secondary endpoint result was used as the basis for a superlative claim — "the only drug" — overstating the trial's conclusions. Without support from the primary endpoint, the word "only" cannot stand.
Source quotation: "Explaining that this is the only drug shown to improve survival prognosis constitutes an exaggerated expression."

Learning from Past Incidents ── Map of 9 chapters

  1. Part 1: Data Misuse and Manipulation That Risk Factual Misrepresentation
  2. Part 2: Selective Data Extraction, Manipulation, and Presentation
  3. Part 3: Claims Without Evidence / Unreliable Data
  4. Part 4: Presenting Unapproved Indications and Dosage Regimens
  5. Part 5 (this chapter): Exaggerated Claims
  6. Part 6: Efficacy-Only Promotion / Safety Information Neglect
  7. Part 7: Disparagement of Competing Products
  8. Part 8: COI Non-Disclosure
  9. Part 9: Other Improper Sales Practices
Key Points
  1. Catchphrases cannot substitute for evidence. Words like "STRONG," "the ultimate," "superior," and "the only one" require backing from head-to-head comparative trials or from primary endpoints. The rhetorical strength of a word is not the same as the scientific strength of the data.
  2. Using numbers outside the trial's designed framework constitutes exaggeration. If the primary endpoint did not reach statistical significance, saying "a difference was seen" is false. Subgroup analyses and secondary endpoints are supplementary; they cannot stand alone as the main basis for an efficacy claim.
  3. Logical leaps and authority transfer are tools for hiding an absence of evidence. The inference chain NSAIDs → blood pressure → renal function, or the response "Professor X also says so" — both conceal rather than address the evidentiary gap. Reaching for authority the moment a claim is challenged is a tacit admission that the scientific basis does not exist.
References
  1. Ministry of Health, Labour and Welfare, "Guidelines on Sales Information Activities for Prescription Drugs" (September 2019)
  2. MHLW Pharmaceutical Safety and Environmental Health Bureau, "Pharmaceutical Sales Information Monitoring Program" Annual Reports, Fiscal Years 2019–2025
  3. Standards for Appropriate Pharmaceutical Advertising (notification from the Director of the Office of Pharmaceutical Safety, MHLW Pharmaceutical Safety and Environmental Health Bureau; revised 2017)
  4. Japan Pharmaceutical Manufacturers Association, "JPMA Code of Practice" (current edition)
  5. Pharmaceuticals and Medical Devices Act, Article 66 (prohibition of exaggerated advertising) and Article 68 (prohibition of advertising unapproved drugs)