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2026-09-24Health

💊 OTC Drug Risk Classes Under Review

Public comment until 0:00 on Sep 24, 2026 | Draft revision of Class 1, Class 2 and Designated Class 2 lists

What is changing?

On August 25, 2026 the Ministry of Health, Labour and Welfare published two draft notifications revising how over-the-counter (OTC) medicines are classified, and opened them for public comment. The first amends the list of "Class 1" and "Class 2" medicines designated by the Minister under Article 36-7, Paragraph 1, Items 1 and 2 of the Pharmaceuticals and Medical Devices Act. The second amends the list of Class 2 medicines designated as "requiring special caution" (Designated Class 2) under Article 1-2, Paragraph 3, Item 5 of the Act's enforcement regulations. OTC medicines are sorted by the side-effect risk of their ingredients, and the class decides how a drug is handled in the store. Class 1 may be sold only by a pharmacist, who must provide written information at purchase. Class 2 and Designated Class 2 may be sold by a pharmacist or a registered seller, with Designated Class 2 carrying extra warnings for children, pregnant women and people with existing conditions. This revision does not change the system itself — it moves individual products between the designation lists. Once finalized, the same familiar medicine may be bought in a different way and come with a different explanation. Comments are accepted from 9:00 on August 25 until 0:00 on September 24, 2026.

👥 Who is affected?

  • Foreign residents who buy OTC medicines at drugstores or pharmacies
  • Households that keep OTC cold, painkiller or stomach medicines on hand
  • Visitors to Japan who buy OTC medicines while traveling
  • People who order medicines through online pharmacies
  • Anyone who wants to submit an opinion (until 0:00 on Sep 24, 2026)

🌏 Impact on foreign residents and visitors

In Japan, the class printed on the box decides whether you can pick a medicine off the shelf yourself or must ask a pharmacist at the counter. If a product moves from Class 2 up to Class 1, you can no longer buy it when no pharmacist is on duty or at stores without one, and you must go through a written explanation at purchase. If it moves down, stores with a registered seller can hand it over more easily. Because that counseling is normally done in Japanese, a language barrier can turn into a "my usual medicine is not available today" moment. For travelers, it directly affects whether a specific medicine is available late at night or near an airport. Designated Class 2 carries extra warnings for pregnant or breastfeeding people, children and those with chronic conditions, so check the label when buying for family members.

💡 Key points to know

1Comments are accepted from 9:00 on Aug 25 until 0:00 on Sep 24, 2026, through the e-Gov public comment page (case number 495260156)
2Before submitting, read the full PDFs of the "comment guidelines" and the "draft notification" — the specific ingredients and products covered are listed there
3Japanese medicine boxes show the class: Class 1, Class ② (Designated Class 2), Class 2, Class 3. Get into the habit of checking the box before buying
4Class 1 medicines can only be bought while a pharmacist is on duty. If you need something urgently, check the store's pharmacist hours in advance
5If you have a chronic condition or are pregnant or breastfeeding, consult the pharmacist or registered seller before choosing a Designated Class 2 medicine; showing your medication record book (okusuri techo) makes it easier
6Questions about the system go to the Pharmaceutical Safety Division, Pharmaceutical Affairs Bureau, MHLW (03-5253-1111 / direct 03-3595-2435)
7This is still a draft. It becomes fixed only after the notification is amended following the comment period, so check the amended notification for the effective date

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