Japan enacted the Cartagena Act in 2003 to implement the Cartagena Protocol on Biosafety to the Convention on Biological Diversity. The Act classifies genetically modified organisms (GMOs) according to two types of uses: use with containment measures and use in open space. Both uses are regulated by the Act, but the latter use is the more regulated of the two.
Although it is legal to plant genetically modified (GM) crops in Japan if certain procedures are followed, no commercial planting of GM crops (aside from ornamental flowers) is occurring in Japan at this time, mainly because the general public is skeptical about the safety of GM crops. Nevertheless, Japan is one of largest importers of GMO foods, though labeling is required if GM crops are used in food in certain cases.
Japan enacted the Act on the Conservation and Sustainable Use of Biological Diversity Through Regulations on the Use of Genetically Modified Organisms (Cartagena Act) in 2003. This Act aims to ensure the precise and smooth implementation of the Cartagena Protocol on Biosafety to the Convention on Biological Diversity (Cartagena Protocol). A person who follows the procedures under the Act and, if necessary, obtains approval from the government is permitted to create, import, or use a genetically modified organism (GMO).
However, because of the general public’s negative views on GMOs, genetically modified (GM) crops are not commercially planted in Japan (see Part II, below). Some prefectures have enacted ordinances that place restrictions on planting GM crops within their jurisdictions (see Part III, below). The only exception is the blue rose, which was genetically engineered by a Japanese company together with an Australian company, and is allowed to be planted and sold in Japan.
Despite the public’s disapproval of GMOs, the government has conducted safety tests and approved 238 foods and food additives that are derived from GMOs. Japan has become one of the world’s biggest GM crop importers.
II. Public and Scholarly Opinion
The general public’s skepticism about the safety of GM crops and foods has found expression in a number of social forums. In a written request to the government regarding the “promotion of knowledge based on science among Japanese people,” the Japanese Society of Plant Physiologists, in conjunction with other organizations, provided an analysis of why consumers persist in their negative views on GM crops. There are many blog sites and websites of private groups that post negative information on GMOs and warn of the dangers of using them. In some quarters there is suspicion that the government is hiding information on GMOs, and newspapers sometimes publish articles that introduce negative views on GMOs.
III. Structure of Pertinent Legislation
As stated in Part I, the Cartagena Act implements the Cartagena Protocol. Domestic food laws regulate the safety of GM food crops (see Part VI, below). Additionally, the Pharmaceutical Affairs Act regulates the assessment of pharmaceuticals that use GMOs.
GMOs are defined in the laws and regulations in slightly different ways, depending on the purpose of the laws and regulations. The definition of a GMO under the Cartagena Act is as follows:
- (2) In this Act, “living modified organism” shall mean an organism that possesses nucleic acid, or a replicated product thereof, obtained through use of the any of the following technologies.
- (i) Those technologies, as stipulated by the ordinance of the competent ministries, for the processing of nucleic acid extracellularly.
- (ii) Those technologies, as stipulated by the ordinance of the competent ministries, for fusing of the cells of organisms belonging to different taxonomical families.
The Act obligates the government to adopt general measures (known as “Basic Matters”) that are designed to prevent adverse effects caused by the use of GMOs and ensure their proper use. The government established these Basic Matters in the form of an ordinance in 2003.
In addition to national legislation, there are local ordinances that regulate GM crops. Eleven prefectures and three municipalities have enacted ordinances or issued guidelines for restrictions on the planting of genetically modified crops within their jurisdictions that go beyond the restrictions established in the Cartagena Act. Local residents’ groups concerned about the safety of GM crops have demanded that such ordinances be passed by their local governments.
Although it is legal to grow government-approved GM crops commercially so long as procedures under the Act and local ordinances are followed, no GM crops (aside from ornamental flowers) are commercially grown in Japan at this time.
IV. Restrictions on Research, Production, and Marketing
The intended use of GMOs dictates the level of restrictions imposed on them under the Cartagena Act. Uses undertaken with the intention of preventing “the dispersal of GMOs into the air, water or soil outside facilities, equipment or other structures” that can prevent such dispersal of GMOs are classified as Type 2 uses and are subject to fewer restrictions. Type 2 uses may include research activities in a laboratory.
For Type 2 uses, the government ministries with jurisdiction over the use of GMOs might issue ordinances that establish containment measures for the GMOs during their use. The nature of the use dictates which ministry has jurisdiction. When such ordinances have been issued, the users must implement any containment measures during the period of use. Thus far, two such ordinances have been issued, one that establishes containment measures for industrial use, and one that pertains to the research and development of GMOs. The following examples illustrate which government entities are in charge of Type 2 uses:
Improvements to crops conducted within facilities, development of live vaccines for animals, etc.
Ministry of Agriculture, Forestry and Fisheries (MAFF)
Viruses for gene therapy, etc.
Ministry of Health, Labour and Welfare (MHLW)
Uses in the experiments of gene recombination in University, etc.
Ministry of Education, Culture, Sports, Science and Technology (MEXT)
Uses in the process of production of industrial enzymes, etc.
Ministry of Economy, Trade and Industry (METI)
Yeast used in the production of alcoholic beverages, etc.
National Tax Agency
Source:Ministry of the Environment (MOE),Biosafety Regulations in Japan5 (2010), http://www. bch.biodic.go.jp/english/cartagena/images/e_cartagena.pdf.
If an intended use does not fall within the purview of an existing ordinance, the user must draft containment measures and obtain confirmation, in advance, from the competent minister.
In order to make sure that the containment measures are properly followed, the Basic Matters obligate Type 2 users of GMOs to endeavor to set up a committee to consider the safe handling of the GMOs in their place of use, according to the characteristics and mode of their use, so that measures for the prevention of adverse effects on biological diversity are appropriately carried out.
If an accident occurs and the Type 2 user cannot take containment measures, the user must immediately take emergency measures and promptly notify the competent minister about the accident and outline the measures taken. The competent minister may then order the user to take emergency measures if they have not as yet been taken.
V. Restrictions on Releasing Organisms into the Environment
The use of a GMO in a field or other open space (Type 1 use) is approved only when the competent minister decides the GMO will not cause any adverse effects on biological diversity. The competent ministries (depending on the purpose and use of GMOs) and the Ministry of the Environment (MOE) jointly manage Type 1 use cases. The MOE is in charge of Type 1 use in all fields because it has the responsibility of deciding whether the uses in an open system will affect biological diversity or not. A Type 1 use applicant must submit a biological diversity risk assessment report that evaluates the extent that the GMO may affect biological diversity. If there is a native species that could be affected, the evaluation examines the possible effects and to what extent the species will be affected. In the case of crops, the possibilities of the GMO’s competition with native wild species, hybridization with native wild species, and production of harmful substances are examined.
A person who wishes to create, import, or use GMOs for Type 1 use must devise a Type 1 Use Rule—that is, draft rules for the use of each type of GMO—and obtain the approval of the competent minister. However, if the GMO is designated by the competent minister as an organism that clearly causes no adverse effect on biological diversity through Type 1 use, the user is not required to draft rules of use. The competent minister must approve the applicant’s Type 1 Use Rule if the minister determines, after consultation with experts, that there would be no unacceptable risks to the preservation of species or populations of wild fauna or flora, or any other adverse effect on biological diversity.
In order to appropriately carry out measures for the prevention of adverse effects on biological diversity, the Type 1 user, like the Type 2 user, must endeavor to set up a committee to consider the safe handling of the GMOs in their place of use, according to the characteristics and mode of their use.
If a person engages in a Type 1 use without a proper Type 1 Use Rule, the competent minister may order the person to take steps to recall the GMOs or take other necessary measures to prevent adverse effects on biological diversity. If an accident occurs and the Type 1 user cannot comply with the Type 1 Use Rule, and an adverse effect on biological diversity could arise, the user must immediately take emergency measures to prevent such an adverse effect. The user must also promptly notify the competent minister of the accident and outline the measures taken. The competent minister may then order the user to take additional emergency measures, if necessary.
When there is a high likelihood that unapproved GMOs have been inadvertently imported, in view of the situation of the producing area or other circumstances, an importer must notify the competent minister to that effect on each occasion. The competent minister may then order the importer to have these organisms tested by a registered inspector.
The Cartagena Act obligates the government to collect, arrange, and analyze information on GMOs, as well as research the effects of their use on biological diversity. The Ministry of Agriculture, Forestry, and Fisheries (MAFF) has annually monitored the spread of escaped imported GM seeds (canola and soy) and their contamination of domestic plants around major shipping ports and roads nearby. In the most recent report (2012), GM canola and soy were observed around the ports, but no contamination of domestic plants was found.
VI. Restrictions on GMOs in Foodstuffs
The safety evaluation standards and production standards of new GM crops to be used for food or food additives are under the jurisdiction of the Ministry of Health, Labour and Welfare (MHLW). The relevant standards are stipulated in MHLW circulars and notifications based on the Food Sanitation Law. Once the MHLW receives an application for the use of a GMO food, the Food Safety Commission (FSC) evaluates the safety of the GM food in terms of human health based on the Food Safety Basic Law. The Expert Committee on Genetically Modified Foods within the FSC conducts safety assessments based on the following standards and policies:
- (1) Standards for the Safety Assessment of Genetically Modified Foods (Seed Plants);
- (2) Policies Regarding the Safety Assessment of Stacked Varieties of Genetically Modified Plants
- (3) Standards for the Safety Assessment of Food Additives Produced Using Genetically Modified Microorganisms
- (4) Policies Regarding the Safety Assessment of Highly Purified Nonprotein Food Additives, Including Amino Acids Produced Using Genetically Modified Microorganisms
According to the Food Sanitation Law, “[i]n order to prevent distribution of GM foods that have not been assessed in Japan, food products are analyzed at quarantines.” The Food Sanitation Law obligates importers of foods, food additives, “apparatuses,” or containers/packages for sale or for use in business to notify the Minister of Health, Labour, and Welfare on each occasion. When such notification is submitted, the food sanitation inspector at the quarantine station inspects the product to examine whether the item meets the regulations under the Food Sanitation Law.
The MAFF is responsible for approving new GM crops for feed use in order to keep livestock safe. The safety test is conducted in accordance with the Act on Feed Safety and Improvement of Quality. The safety of food derived from livestock that are fed GM crops is examined by the FSC.
As a part of the legal safety assessment system under the Food Sanitation Law, there is a labeling system for GM foods and two corresponding laws that include provisions on labeling: the Japanese Agricultural Standards Law (JAS Law) and the Food Sanitation Law. The two labeling systems are almost the same, and only one label is required. Eight crops/vegetables/fruits (soy, corn, potato, canola, cotton seed, alfalfa, beet, and papaya) and thirty-three processed foods that include more than 5% of these eight foods in weight are subject to labeling. The 5% tolerance applies only to GM varieties that have been approved in Japan. A summary of the labeling system follows.
1. Mandatory Labeling
GM products whose compositions or nutritional values are the same as their conventional counterparts, and processed food in which genetically modified DNA or proteins derived from the DNA can be detected even after processing of GM products, are subject to mandatory GM labeling. There are two types of cases:
- (a) GM products that have been handled to preserve their identity by segregating them from non-GM products (“IP handling”)
- (b) Products for which IP handling has not been conducted (e.g., in the case of voluntary labeling, discussed below, soybeans are labeled “GM Ingredients,” “GM Ingredients Not Segregated,” or “Non-GM”)
In addition, food items that are considerably different in composition or nutritional value from their conventional counterparts and the processed foods made from them, which require labeling (e.g., soybeans with high oleic acid, labeled “soybeans (High Oleic Acid/GMO),” and corn with a high lysine content)
2. Voluntary Labeling
Food in which genetically modified DNA or proteins derived from such DNA cannot be detected after processing, such as oil and soy sources, are not subject to mandatory GM labeling and can be labeled as not containing GM products. In addition, products certified as being free of GM products through IP handling can be labeled as not containing GM products.
3. Prohibited Labeling
Agricultural products that have no variety developed by recombinant DNA techniques, and foods processed from such products, cannot have a term on their labels that suggests they are non-GM. The reason is that if such labeling were allowed, consumers might think that GM versions of such products exist in Japan and that they are thus buying a non-GM version. In such cases, it is possible to add a description about the product to prevent misunderstandings. For example, it is permissible to add a description to a bag of rice, next to the legally required labeling, stating that “[a]t present, there is no GM rice on the market.” 
VII. Liability Regime
There is no special civil liability regime in relation to the development, use, or release of GMOs. The Cartagena Act provides administrative and criminal sanctions against violators of the Act.
VIII. Judicial Decisions / Prominent Cases
There was a case in 2005 in which farmers in a city sued a research institution that owned lands in the same city to stop the experimental planting of genetically modified rice outside a building on that land. The institution was planting rice, in conformity with Cartagena Act regulations, that is supposed to create a protein to kill a rice pathogen. The plaintiffs claimed that a pathogen that is immune to the protein may be created and thereby endanger humans and the environment. However, the courts held that the plaintiffs had not successfully proved their claims and dismissed the case.
Foreign Law Specialist
 Act on the Conservation and Sustainable Use of Biological Diversity through Regulations on the Use of Living Modified Organisms (Cartagena Act), Act No. 97 of June 18, 2003. An English translation of this Law is available on a website managed by the Ministry of Justice, at http://www.japaneselawtranslation.go.jp/law/detail_main?re= 02&vm=02&id=132 (last visited Oct. 22, 2013).
 Id. art. 1 (citing the Cartagena Protocol, Jan. 29, 2000, http://treaties.un.org/doc/Treaties/2000/01/20000129% 2008-44%20PM/Ch_XXVII_08_ap.pdf).
 Shokubutsu: Sekai hatsu! baiotekunorogi de “aoi bara” no kaihatsu ni seikou! [Plants: First in the World! Success of Development of “Blue Rose” by Biotechnology!], Suntory, http://www.suntory.co.jp/company/research/high tech/blue-rose/history.html (last visited Nov. 18, 2013).
 Ministry of Health, Labour and Welfare, Pharmaceutical and Food Dept., Food Safety Sec., Chart of GM Foods and Food Additives that Went Through Safety Examinations (Oct. 17, 2013), http://www.mhlw.go.jp/topics/ idenshi/dl/list.pdf.
 Tony C. Dreibus & Rudy Ruitenberg, Wheat Falls as Japan Suspends U.S. Imports on Biotech Crop Find, Bloomberg (May 30, 2013), http://www.bloomberg.com/news/2013-05-30/wheat-drops-as-global-crop-outlook-counters-u-s-planting-delays.html.
 Japanese Society of Plant Physiologists, Teigen: “idenshi kumikae shokubutsu no shakai ni okeru tekisetsu na juyō o susumeru taisei o motomu” [Proposal: “Requesting System to Support Adequate Acceptance of GM Food by the Society”] at 3, http://www.s.affrc.go.jp/docs/commitee/gm/4kai/pdf/siryo1.pdf (last visited Oct. 18, 2013).
 Blogs are very popular in Japan. See Chris Salzberg, Japan: Number 1 Language of Bloggers Worldwide, Global Voices (Apr. 16, 2007), http://globalvoicesonline.org/2007/04/16/japan-number-1-language-of-bloggers-worldwide/.
 See GM shokuhin, shohisha no “shiru kenri” ni dou kotaeruka [GM Foods, How to Respond to Consumers’ “Right to Know”], Japan Agricultural Communications (June 11, 2013), http://www.jacom.or.jp/news/2013/06/news 130611-21193.php.
 Yoshiyuki Ashida, Mainichi shinbun no rensai shokutaku doko e: idenshi kumikae [How Foods on Table at Home Change According to Mainichi Newspaper: Genetically Modified Food], Yasashii baio tekunoroji [Easy Biotechnology] (Nov. 10, 2009), http://yoshibero.at.webry.info/200911/article_23.html. The author, Yoshiyuki Ashida, is a professor who comments on articles from the Mainichi Newspaper on his blog site.
 Cartagena Act, Act No. 97 of June 18, 2003, art. 2, para. 2, http://www.japaneselawtranslation.go.jp/law/detail_ main?re=02&vm=02&id=132.
 Id. art. 3.
 Basic Matters Under the Provisions of Article 3 of the Law Concerning the Conservation and Sustainable Use of Biological Diversity Through Regulations on the Use of GMOs (Basic Matters), MOF, MEXT, MHLW, MAFF & MOE Ordinance No. 1 of 2003, http://www.bch.biodic.go.jp/english/law.html (click “Word” icon next to the title).
 Yoshiko Sasaki, Idenshi kumikae gijutsu to shoku no anzen / anshin [Safety and Feeling of Safety on GM Technology and Foods], 1st and 2nd Meetings for Food Safety and Feeling of Safety, Yamanashi Pref. (Nov. 15 & Dec. 20, 2012), at 25, http://www.pref.yamanashi.jp/shoku-portal/communication/documents/tudoikouen-sassa_1.pdf.
 Many resident groups’activity reports are available through general Internet searches. See, e.g., Jiro Urushihara, Jorei de chiiki no anzen/anzhin o kakuho suru—idenshi kumikae o meguru ho (5) [Securing Safety/Feeling of Safety of Residents by Local Ordinances—Laws Concerning GM (5)], Kagaku gijutsu no anekudoto [Anecdote of Science and Technology] (June 11, 2012), http://sci-tech.jugem.jp/?eid=2416.
 Idenshi kumikae sakumotsu wa nihon de jissai ni saibai sarete iru no desu ka? [Are GM Crops Actually Grown in Japan?], Monsanto Japan, http://www.monsanto.co.jp/question/03/03/ (last visited Nov. 1, 2013).
 Cartagena Act, Act No. 97 of June 18, 2003, art. 2, paras. 5 & 6, arts. 4 & 12, http://www.japaneselawtranslation. go.jp/law/detail_main?re=02&vm=02&id=132.
 Id. art. 12.
 Ordinance to Designate Measures to Prevent Dispersal of GMOs During Their Industrial Use Among Type 2 Use, Ministry of Finance, MHLW, MAFF, METI & MOE Ordinance No. 1 of 2004.
 Ordinance to Designate Measures to Prevent Dispersal of GMOs During Their Type 2 Use for Research and Development Purposes, MEXT & MOE Ordinance No. 1 of 2004.
 Cartagena Actart. 13.
 Basic Matters, supra note 12, § II, 2.
 Cartagena Act art. 15.
 Id. art. 4, para. 2.
 Ministry of the Environment (MOE),Biosafety Regulations in Japan9–10 (2010), http://www. bch.biodic.go.jp/english/cartagena/images/e_cartagena.pdf.
 Cartagena Act art. 4, para. 1.
 Id. art. 4, para. 5.
 Basic Matters, supra note 12, § II, 2.
 Cartagena Act art. 10, para. 1.
 Id. art. 11.
 Id. art. 16.
 Id. art. 17.
 Id. art. 34.
 Press Release, MAFF, “Heisei 24 nendo idenshi kumikae shokubutsu jittai chōsa” no kekka ni tsuite [Regarding the Result of “Research on GM Plants in Fields in Fiscal Year 2012”] (Sept. 24, 2013), http://www.maff.go.jp/j/ press/syouan/nouan/130924.html.
 Food Sanitation Law, Act No. 233 of 1947, last amended by Act No. 70 of 2013, art. 7, para. 1; Standards of Foods and Food Additives, Ministry of Health and Welfare Notification No. 370 of 1959, amended by MHLW Notification No. 232 of 2000, http://www.mhlw.go.jp/topics/idenshi/anzen/kokuji.html.
 Food Safety Basic Law, Act No. 48 of 2003, last amended by Act No. 74 of 2011, arts. 11 & 23, English translation available at http://www.fsc.go.jp/english/basic_act/fs_basic_act.pdf.
 Procedure for Safety Assessment, MHLW, http://www.mhlw.go.jp/english/topics/foodsafety/dna/01.html (last visited Oct. 23, 2013).
 Foods Produced by Recombinant DNA Techniques, MHLW, http://www.mhlw.go.jp/english/topics/foodsafety/ dna/index.html (last visited Oct. 25, 2013).
 Food Sanitation Law art. 27.
 Id. art. 28. See Development of Imported Foods Monitoring and Guidance Plan for FY 2013, MHLW Notice No. 0318 Article 1 of the Department of Food Safety (Mar. 18, 2013), http://www.mhlw.go.jp/topics/yunyu/keikaku/ 13_en.html.
 Act on Feed Safety and Improvement of Quality, Act No. 35 of 1953, last amended by Act No. 8 of 2007, art. 3. Ordinance on Act on Feed Safety and Improvement of Quality, MAFF Ordinance No. 35 of 1976, last amended by MAFF Ordinance No. 60 of 2013, Tables 1, 1(1)(shi)(su) & (2)(ko), 2 & 3(8).
 Ideas for Safety Evaluations of Feed and Feed Additives That Are or Include GMOs, Food Safety Commission Decision (May 6, 2004), http://www.fsc.go.jp/senmon/idensi/gm_siryoukijyun.pdf.
 Law Concerning Standardization and Proper Labeling of Agricultural and Forestry Products (JAS Law), Act No. 175 of 1950, last amended by Act No. 70 of 2013, art. 19-13, translated by MAFF at http://www.maff.go.jp/e/jas/ pdf/jaslaw01.pdf; Processed Food Quality Labeling Standards, MAFF Notification No. 513 of 2000, last amended by Consumer Affairs Agency Notification No. 5 of 2012, art. 7, para. 1; Fresh Produce Quality Labeling Standards, MAFF Notification No. 514 of 2000, last amended by MAFF Notification No. 126 of 2008, art. 7, para. 1; Labeling Standards on GM Food Set by Minister of MAFF Based on Article 7, Paragraph 1 of Processed Food Quality Labeling Standards and Article 7, Paragraph 1 of Fresh Produce Quality Labeling Standards (Labeling Standards on GM Food Set by Minister of MAFF), MAFF Notification No. 517 of 2000, last amended by MAFF Notification No. 9 of 2011, http://www.caa.go.jp/jas/hyoji/pdf/kijun_03.pdf, available in English translation (as last amended by MAFF Notification No. 1173 of October 1, 2007), at http://www.maff.go.jp/e/jas/labeling/pdf/ modi01.pdf.
 Food Sanitation Law, art. 19, para. 1, Cabinet Office Ordinance on Labeling Standards Based on Food Sanitation Law (Cabinet Office Ordinance on Labeling Standards), art. 19, para. 1, Cabinet Office Ordinance No. 45 of 2011, art. 1, para. 1, item 12 & Table 1, http://www.cao.go.jp/consumer/history/02/kabusoshiki/syokuhinhyouji/doc/ 130530_shiryou2-1.pdf.
 Consumer Affairs Agency, Food Labeling Sec., Shokuhin hyōji ni kansuru kyōtsū Q&A (dai 3 shū: idenshi kumikae shokuhin ni kansuru hyōji ni tsuite) [Common Q&A on Food Labeling (Part 3: Regarding Labeling of GM Food)] (Dec. 2003, amended Oct. 2007 & Mar. 2010), http://www.caa.go.jp/foods/pdf/syokuhin244.pdf.
 Labeling Standards on GM Food Set by Minister of MAFF Based on Article 7, Paragraph 1 of Processed Food Quality Labeling Standards and Article 7, Paragraph 1 of Fresh Produce Quality Labeling Standards (Labeling Standards on GM Food Set by Minister of MAFF), MAFF Notification No. 517 of 2000, last amended by MAFF Notification No. 9 of 2011; Cabinet Office Ordinance on Labeling Standards, supra note 43.
 Cabinet Office Ordinance on Labeling Standards, supra note 45, art. 14, item 1.
 See Labeling Scheme for Genetically Modified Foods in Japan, MAFF, http://www.maff.go.jp/e/jas/labeling/pdf/ modi02.pdf (last visited Oct. 30, 2013).
 Labeling Standards on GM Food Set by Minister of MAFF, supra note 45, art. 3, para. 1(1) & para. 2(1); Cabinet Office Ordinance on Labeling Standards, supra note 45, art. 1, para. 2, item 40.
 Labeling Standards on GM Food Set by Minister of MAFF, supra note 45, art. 3, para. 1(2) & para. 2(2).
 Id. arts. 3 & 4; Cabinet Office Ordinance on Labeling Standards, supra note 45, art. 1, para. 7.
 Labeling Standards on GM Food Set by Minister of MAFF, supra note 49, art. 5.
 Consumer Affairs Agency, Food Labeling Sec., Shokuhin hyōji ni kansuru kyōtsū Q&A (dai 3 shū: idenshi kumikae shokuhin ni kansuru hyōji ni tsuite) [Common Q&A on Food Labeling (Part 3: Regarding Labeling of GM Food)] (Dec. 2003, amended Oct. 2007 & Mar. 2010), at 42.
 Ine jikken chushi, baisho mitomezu: idenshi kumikae sosho [Injunction of Rice Experiment and Damages Were Not Awarded: Genetically Modified Rice Case], 47News (Oct. 1, 2009), http://www.47news.jp/CN/200910/ CN2009100101000504.html. See also Kindan no kagaku saiban [Trial of Forbidden Science], http://ine-saiban.com/ (last visited Oct. 23, 2013).
Last Updated: 12/30/2020