I’ll introduce information for understanding coupons and the Act Against Unjustifiable Premiums and Misleading Representations.

Q&A About Premiums and Coupons | Consumer Affairs Agency

Q23 Our company publishes information about restaurants and other establishments in an advertising format, and some restaurant advertisement pages have printed coupons such as "500 yen off from meal price," "○○% off from meal price," "Free drink for dining customers," etc. We call this a "free paper." We want to distribute this free paper at train station gates and on busy streets, but does this free paper fall under premium items according to the Act Against Unjustifiable Premiums and Misleading Representations?

A Publishers of such free papers are not subject to premium regulations. However, when stores featured in the free paper provide goods to customers who bring the coupons printed in the free paper, premium items are considered to be provided in individual transactions between these stores and customers, and general premium regulations apply individually to premium provision schemes by these stores (if the coupon is a discount voucher usable at the store, it corresponds to economic benefits similar to price reduction, and premium regulations do not apply).

Source: 景品に関するQ&A | 消費者庁

Explanation of Act Against Unjustifiable Premiums and Misleading Representations Regulations for Coupon Customer Acquisition

Coupons and the Act Against Unjustifiable Premiums and Misleading Representations

Coupons not subject to Act Against Unjustifiable Premiums and Misleading Representations regulations Basically, coupons that do not fall under "premium items" as defined by the Act Against Unjustifiable Premiums and Misleading Representations are naturally not subject to regulation.

Example) Next-time 20% OFF coupon for purchases of 1000 yen or more

“Price discounts” are stated in the notice as economic benefits recognized as discounts or after-sales service in light of normal business practices, so they are not included in premium items. Therefore, they do not constitute premium items, and amount-based discount coupons that are commonly seen on EC sites are frequently used.

Source: クーポン集客に係る景品表示法の規制内容について解説 | 【アフィリエイトA8.net】日本最大級の広告主数・サイト数のアフィリエイトサービス

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