CCHR REPORT: ADHD LABELING AND TREATMENT OF CHILDREN IN JAPAN 1

2018

ADHD labeling
and treatment of
children in Japan

CITIZENS COMMISSION ON HUMAN RIGHTS JAPAN

CITIZENS COMMISSION ON HUMAN RIGHTS EUROPE

January 2018
CCHR REPORT: ADHD LABELING AND TREATMENT OF CHILDREN IN JAPAN 2
 CCHR REPORT: ADHD LABELING AND TREATMENT OF CHILDREN IN JAPAN 3

Introduction
Children in Japan are being labeled with the psychiatric diagnosis attention-
deficit/hyperactivity disorder (ADHD) and given psychiatric drugs in order to
control the symptoms labeled as ADHD, just as in many European and American
countries. The rate of the drugs used are different than those in Europe and the
USA which is caused mainly by earlier abuses of psychostimulant drugs causing
some of these to be banned and secondly a zero tolerance to drugs use in general
(the psychostimulants used in the control of ADHD labeled children are actual
drugs with a high abuse potential).

Large international pharmaceuticals are increasingly focusing on releasing new

types of drugs on the Japanese market that can be prescribed to children labelled
with ADHD such as lisdexamfetamine and guanfacine (sold under the name
Intuniv). The Japanese market is being described as “the world’s third-biggest
market for ADHD treatments” and is growing at more than 20 percent annually.1

Japanese children in early studies were found to be among those less considered
fulfilling the diagnostic criteria for attention-deficit/hyperactivity disorder (ADHD).

Yet, marketing efforts and American psychiatrists have promoted the American
concept of various behavioural symptoms clustered together and called ADHD, to
a degree, that a large number of parents have taken on the concept. In recent
years normal children, who sometimes may behave “unnormal” are being noticed
as suffering from the symptoms which are called “ADHD” by their parents.

A study of preschool children in Niigata City, Japan exemplify this. A questionnaire

survey conducted in Niigata City in 2003, involved an evaluation of ADHD
symptoms by their school teachers. A second survey, conducted in 2006, involved
an evaluation of the symptoms by parents in the same city. The teacher survey
included 9.956 children, and the parent survey included 7.566 children. Parents
and teachers assessed ADHD symptoms in children using a 14-item questionnaire
based on the American Psychiatric Association’s diagnostic manual DSM-III-R. The
parent survey showed that 31.1% of the parents believed their child had ADHD
while the teachers believed it was 4.3% of the children.2

1 Shire, Shionogi's ADHD drug for adults clears late-stage trial in Japan; Reuters Health News – Staff reporting by Sam

Nussey, editing by Edwina Gibbs; 20 Sept 2017.

2 Environ Health Prev Med., Mar 2009; 14(2): 150–154. doi: 10.1007/s12199-008-0075-4. Prevalence of attention-

deficit/hyperactivity disorder (ADHD) symptoms in preschool children: discrepancy between parent and teacher
evaluations. By Yukio Soma, Kazutoshi Nakamura, Mari Oyama, Yasuo Tsuchiya, and Masaharu Yamamoto, Department
of Community Preventive Medicine, Niigata University Graduate School of Medical and Dental Sciences.
 CCHR REPORT: ADHD LABELING AND TREATMENT OF CHILDREN IN JAPAN 4

The study concluded that “the large difference between the estimated prevalence
of ADHD symptoms in Japanese preschool children from teacher and parent
surveys suggests that compared to teachers, parents consider their children’s
symptoms much more serious. Thus, parental evaluation of ADHD symptoms
using DSM criteria may be inappropriate for ADHD screening.”

Yet, the more important question is what made these parents believe their own
child behaved unnormal to a degree that their opinion would label nearly 1/3 of
them with a psychiatric disorder. A disorder which symptoms in Japanese children
at the same time were found to be among the lowest in the world. 3

Such misconceptions could result in harm, including unjustified drugging with

psychotropic drugs. This has to be seen in view of a 2003 survey which found that
most Japanese doctors initiated drug treatment for ADHD at a very low threshold
of symptoms found. It was found that psychotropic drugs were often used to
“quell nuisances caused by children with ADHD, such as disturbing classes,
breaking rules, or fighting, instead of improving hardwired difficulties in children
with ADHD, such as attention deficit or lower academic performance.” 4

The diagnosis of ADHD, is not based on actual medical tests or identifiable

malfunctions in the body, but is entirely a subjective interpretation of the severity
of a number of identified behavioral traits which are considered symptoms of the
disorder. Some of these specific behavioural pattern are seen as unwanted. In
Japanese culture, it is important to respect other people’s personal space. When
a child is behaving very actively/impulsive or “interrupts and intrudes on others”
(which is one of the defining symptoms of ADHD), this may be seen as very
unwanted. The parents of a child who so behaves are often very concerned about
this, because it breaks the cultural norm. As such, parents of a child with this
symptom may be more inclined to getting their child diagnosed with ADHD, and
they would be more inclined to give their child a drug to stop this behaviour.

In consequence new guidelines for ADHD treatment were formulated in 2003

stressing that parents, doctors, and teachers should keep in mind that in the case
psychotropic drugs are to be used they have to be “administered on behalf of

3 “The main finding was that the variation in prevalence of ADHD…. The North American rate (6.2%) only slightly

exceeded the European rate (4.6%). The highest rates emerged from Africa (8.5%) and South America (11.8%).
Corroboration comes from a dimensional ADHD scale used in 21 countries. Japanese and Finnish children scored
lowest, Jamaican and Thai children scored highest.” - Am J Psychiatry. 2007 Jun; 146(6): 856–858. doi:
10.1176/appi.ajp.164.6.856; Why does the worldwide prevalence of childhood attention deficit hyperactivity disorder
matter? By Terrie Moffitt and Maria Melchior; Social, Genetic and Developmental Psychiatry Centre King's College,
University of London, Institute of psychiatry, London, GB.
4 Kanbayashi Y, Saito K, Kita M: Japanese Guideline for Diagnosis and Treatment of AD/HD [in Japanese]. Tokyo: Jiho;

2003.
 CCHR REPORT: ADHD LABELING AND TREATMENT OF CHILDREN IN JAPAN 5

children with ADHD and not on behalf of those around them.”5 These guidelines
were changed in 2006, and again in the FY2014 to FY2016.
American psychiatric studies nevertheless note that “in Japan, treatment with
medication for attention-deficit/hyperactivity disorder (ADHD) is less favorable
than psychosocial treatment, as in Europe.”6 And “In many countries, the current
mainstay of ADHD-related psychopharmacotherapy involves psychostimulants,
despite recent abuse issues with Ritalin (Novartis, Basel, Switzerland). In Japan,
amphetamine-type stimulants that are available in other countries are treated as
narcotics; their manufacture, storage, and use are strictly prohibited by the
Stimulant Drugs Control Law enacted in 1951.” It is noted that “only one
stimulant (long-acting methylphenidate) is now available in Japan.”7

Psychostimulant drugs use in Japan

After being widely used by the Japanese military and their allies through WWII, all
stimulants were banned by the Japanese government in 1951. This occurred as a
consequence of finding that they were strongly addictive. Since then, a zero-
tolerance drug policy has since been instilled on many of the psychostimulants
such as amphetamine by the Health, Labor, and Welfare Ministry.
In 1961, the psychostimulant drug methylphenidate (sold as Ritalin) was
approved to treat depression and depressive neurosis. In those days, regulation
by the Japanese government was not as strict as it is today.8
After methylphenidate became available in Japan, cases of abuse were soon
reported. In 1973, a warning that “methylphenidate should be given cautiously
because of a possible risk for dependency” appeared in the drug information.
In the 1960s, the first psychiatric clinical trials of methylphenidate, as well as
dextroamphetamine, were completed in the United States, claiming efficacy for
hyperactivity, impulsivity, and moodiness. Following these American trials, to
reconfirm its efficacy for the Japanese population, uncontrolled trials of
methylphenidate for ADHD symptoms were performed by Japanese child
psychiatrists. They subsequently demanded that ADHD should be added to the
indication for methylphenidate use in Japan, which was rejected.9

5 Ditto.

6 SpringerLink - Current Attention Disorders Reports, March 2009, Volume 1, Issue 1, pp 21 –28; Psychopharmacology

for attention deficit/ hyperactivity disorder in Japan; by Toshinobu Takeda, MD, Ph.D., Center for Management of
ADHD, Children’s Hospital of Philadelphia, Philadelphia, USA.
7 Ditto.

8 Ditto.

9 Ditto.
 CCHR REPORT: ADHD LABELING AND TREATMENT OF CHILDREN IN JAPAN 6

In Japan, methylphenidate (Ritalin) was then prescribed for ADHD as an off-label

use (following a medical judgement not in accordance with the official approval)
until 2007, when it was prohibited for ADHD treatment.
Cases with methylphenidate addiction or dependency have been found in Japan
since the 1980s. Largely thanks to the Internet, an increasing number of
methylphenidate addiction cases have been identified.
Almost all reported cases of methylphenidate abuse were triggered by
prescriptions from medical facilities intending to improve depressive states. The
cases further revealed that psychological dependence of methylphenidate was a
rapid effect and that it easily became severe.
Some warnings against methylphenidate abuse/dependence were published in
the pursuing time; some reported that methylphenidate abusers/dependents in
search of large quantities of Ritalin visited multiple psychiatric clinics, feigned
psychiatric disorders, and even falsified prescriptions using color copiers.
In 2007, prescribed Ritalin for inappropriate cases became a public concern when
it was uncovered by a major Japanese newspaper – The Yomiuri – that, without
proper medical examination, a clinic in Tokyo prescribed massive doses of Ritalin
to probable Ritalin abusers/dependents.
In October 2007, the Ritalin indication was limited to narcolepsy only.
Subsequently, the Ritalin Distribution Control Panel, a third-party organization,
was established at the end of 2007. The panel decided that Ritalin must be
prescribed by registered physicians only from registered pharmacies.
Shortly after in October the same year, it was decided that Concerta, another
methylphenidate containing drug, may be prescribed for ADHD. The psychoactive
substance in Concerta, which came on the market many years after Ritalin first
was promoted, is released slowly which is claimed to decrease the abuse
potential. This was the first time that a drug was officially approved for the
treatment of ADHD. It may be used for children six years or older. Only registered
psychiatrist or pediatrician who obtained a permission can prescribe this drug.
Ritalin sales have drastically plunged since distribution control began in early
January 2008.10
In 2009 Strattera (Atomoxetine), a non-stimulant drug in the same drug
classification group as methylphenidate, was approved for the management of
ADHD symptoms.
In 2017 another non-stimulant drug Intuniv (Guanfacine) was approved for ADHD.

10 Ditto.
 CCHR REPORT: ADHD LABELING AND TREATMENT OF CHILDREN IN JAPAN 7

Psychotropic drug use increasing for years

In the mid-2000s and more recently a growing number of Japanese children are
being prescribed psychotropic drugs to treat attention deficit hyperactivity
disorders (ADHD), according to a study by government-funded medical institutes.
In particular, the number of ADHD drug prescriptions for patients aged 13 to 18
years old surged 2,49 times between two three-year periods covering 2002-2004
and 2008-2010. It was specifically noted this occurred despite some of them
wasn’t approved for use by children, the study said.11
“Frankly, this is an unfortunate situation for the medical community” because
doctors have to take risks to provide some psychotropic drugs to underaged
patients, said Yasuyuki Okumura, a researcher at the Institute for Health
Economics and Policy and co-author of the research paper.12
The paper, which examined a total of 233.399 prescriptions issued by hospitals
and clinics from 2002 to 2010, was published in November 2014 in the Japanese
medical journal Seishin Shinkeigaku Zasshi (Journal for the Japanese Society of
Psychiatry and Neurology).
Doctors in Japan dealing with children who are suffering from mental problems
have long prescribed psychotropic drugs approved only for adults. They do this
despite it is known doing so involves risks for the child. Okumura said that in
Japan few clinical studies exist on psychotropic drugs for children, unlike in the
U.S. and Europe, where clinical trials covering children are legally stipulated.

Fig. 1. Number of pills sold for the management of ADHD symptoms in Japan

Psychotropic drug use for ADHD in 2014

14.000.000

12.000.000

10.000.000

8.000.000
Concerta
6.000.000
Strattera
4.000.000

2.000.000

0
0-4 y.o. 5-9 y.o. 10-14 y.o. 15-19 y.o

11 More Japanese children being prescribed psychotropic drugs; The Japan Times, by Shusuke Murai - staff writer; 14

January 2015.
12 Ditto.
 CCHR REPORT: ADHD LABELING AND TREATMENT OF CHILDREN IN JAPAN 8

Table. 1. Number of pills sold for the management of ADHD symptoms in Japan 13
0-4 y.o. 5-9 y.o. 10-14 y.o. 15-19 y.o
Strattera 6.777 4.307.326 9.544.297 3.364.281
Concerta 0 2.766.744 4.125.325 1.366.601

Okumura and his team also found that the number of ADHD drug prescriptions
for 6- to 12-year-old children during the years 2008-2010 increased 84 percent
compared to the figure during 2002-2004.14

Fig. 2 Sale of Strattera (atomoxetine) in million Yen (JPY)15

25000 22900

20000 18300

13900
15000

9700
10000
6200
4200
5000
2300
540
0
2009 2010 2011 2012 2013 2014 2015 2016

Pharmaceutical company lines to government

The international pharmaceutical company Shire – that is specifically targeting
the ADHD market – has been looking to Japan to boost its growing ADHD drugs
business. The Japanese market for ADHD treatments is growing at more than 20
percent annually, the company stated when it in September 2017 announced that
its ADHD drug, Intuniv, sold by its Japanese partner Shionogi & Co Ltd had met its

13 Source: NDB Open Data Japan. In 2009, the Ministry of Health, Labour and Welfare (MHLW) started operating the

National Database of Health Insurance Claims and Specific Health Checkups of Japan (NDB). The database accumulates
health insurance claims every month and specific health checkup data every year, resulting in one of the most
exhaustive healthcare database of a national size in the world. The first “NDB Open Data Japan” consists of
fundamental spreadsheets that sum up the claim data of the fiscal year 2014 and the specific health checkup data of
the fiscal year 2013. http://www.mhlw.go.jp/file/06-Seisakujouhou-12400000-Hokenkyoku/0000177764.pdf
14 Ditto.

15 Source: press releases of the pharmaceutical company Eli Lilly Japan K.K. which produce Strattera.

http://news.lilly.co.jp/news_list.html?page=1&category=7
 CCHR REPORT: ADHD LABELING AND TREATMENT OF CHILDREN IN JAPAN 9

main goal in a late-stage trial of adults in Japan.16 The drug was already approved
for children in Japan earlier in 2017.
The company with the expected release of two of its ADHD drugs to the Japanese
market has built up a strong relationship with a number of governmental
administrations. The Osaka Prefectural government (the second largest regional
government in Japan) formed a partnership with Shionogi & Co., Ltd. about the
field of enlightenment of developmental disorder on 25 January 2017.17
The Osaka Prefectural government further carried out a special event entitled
“Symposium for developmental disorders: World Autism Awareness Day in OSAKA
2017” with Shionogi on 7 April 2017.18
Shionogi while working on these events obtained the manufacturing and
marketing approval from the Japanese Ministry of Health, Labor and Welfare for
their pediatric ADHD drug Intuniv® tablets (1 mg/3 mg) on 30 March 2017.19
Shionogi has also applied for approval to manufacture and sell the drug
“lisdexamfetamine mesilate” (sold as Vyvanse in many countries) on 13 April
2017.20
Another regional government, Shiga Prefectural government, is about to form a
partnership with Shionogi.21

State party periodic reports omit data

The CRC in consideration of the third periodic report of Japan (CRC/C/JPN/3) in
June 2010 noted an increase of ADHD diagnoses and in view of this recommended
in its Concluding observations (61.) “that the State party monitor the trends in
the numbers of ADHD diagnoses and ensure that research in this area is
conducted independently of the pharmaceutical industry.”
The State party acknowledged a need for monitoring the numbers of ADHD
diagnoses, stating in its fourth and fifth period reports (CRC/C/JPN/4-5 of 1
November 2017) that (107.) “The number of ADHD patients is identified through
patient research.” And the state party added that: “From FY2014 to FY2016, the

16 Shire, Shionogi's ADHD drug for adults clears late-stage trial in Japan; Reuters Health News – Staff reporting by Sam

Nussey, editing by Edwina Gibbs; 20 Sept 2017.

17 http://www.pref.osaka.lg.jp/gyokaku/kohmin/shionogi.html

18 http://www.pref.osaka.lg.jp/hodo/attach/hodo-26330_4.pdf

19 http://www.shionogi.co.jp/en/company/news/2017/pmrltj0000003ahh-att/e170330_1.pdf

20 http://www.shionogi.co.jp/en/company/news/2017/pmrltj0000003b16-att/e170413.pdf

21 Chunichi Newspaper web news of 19 December 2017,

http://www.chunichi.co.jp/article/shiga/20171219/CK2017121902000003.html
 CCHR REPORT: ADHD LABELING AND TREATMENT OF CHILDREN IN JAPAN 10

government created a medication guideline for children and adolescents with

disorders, including developmental disorders."
The state party of Japan further provided some statistical Information among
others that the number of children with ADHD who are enrolled in special
instruction in resource rooms (elementary and junior high schools) is 16.886.
The state party in other words is monitoring at least one part of the children being
labeled with ADHD, but it does not comment or report on children being treated
mainly with psychotropic drugs. The state party further does not report on the
research and measures related to the handling of these children including the
writing of the new guidelines were done "independently of the pharmaceutical
industry."

Guidelines written by professionals with

financial ties to the pharmaceutical industry
The reason for this omission of the state party is most likely because this wasn’t
the case. The guideline was formulated by well-known psychiatrists of which most
have financial ties with the pharmaceutical industry.
To exemplify this, is the case of Dr. Hironobu Ichikawa who was the president of
the Japanese Society of ADHD (April 2010 to March 2016). He was also a special
adviser to the Tokyo Metropolitan Children’s Medical Center and president of
Japan’s Developmental Disorders Network (the biggest developmental disorders’
group). While holding these positions Dr. Ichikawa did not report on getting
money from pharmaceutical companies. This eventually became the subject of an
exposure when an investigation was carried out by the Tokyo Metropolitan
assembly on 9 March 2016.
According to an article in the Asahi Newspaper (10 March 2016), Dr. Hironobu
Ichikawa got about 7 million Yen from two pharmaceutical companies in FY2013
to FY2014. The companies were Eli Lilly Japan K.K. and Janssen Pharmaceutical
K.K. which are both selling ADHD drugs. Not revealing this is a violation of the
applicable conflict of interest regulations.
Dr. Hironobu Ichikawa was one of the authors of the treatment guideline for
children and adolescents with disorders, including developmental disorders
written in FY2014. He mentioned the result of ADHD drug therapy in Tokyo
Metropolitan Children’s Medical Center in his contributions to the guidelines.
 CCHR REPORT: ADHD LABELING AND TREATMENT OF CHILDREN IN JAPAN 11

This guideline was made possible by a research grant provided by the Health and
Labour Sciences. Any researchers and organizations receiving Health and Labour
Sciences Research Grants have to declare their conflicts of interests. When the
Ministry of Health, Labour and Welfare accepted the contribution of Dr. Ichikawa
as a part of the guideline in FY2014, it considered there was no problem.
And the state party of Japan even mentioned this very guideline to the CRC as an
argument that actions are taken: “From FY2014 to FY2016, the government
created a medication guideline for children and adolescents with disorders,
including developmental disorders.” The state party however omitted stating
that the majority of the psychiatrists who formulated these guidelines including
Dr. Hironobu Ichikawa were having published financial ties to the pharmaceutical
industry.
It is not only individual ADHD researchers, experts and government advisors who
are having financial ties to the pharmaceutical industry. The Japanese Society of
ADHD is the expert medical association in the field of research of ADHD. This
group has also been sponsored by the aforementioned two pharmaceutical
companies. Eli Lilly Japan K.K. (which is the company selling the drug Strattera)
sponsored the Society of ADHD with a total of 2.000.000 JPY in 2013 and
9.904.762 yen in 2014. Janssen Pharmaceutical K.K. (the company which are
selling Concerta) sponsored the Society of ADHD with 1.500.000 yen in 2013 and
3.500.000 yen in 2014. The later years has not yet been publicized.

Recommendations
CCHR is of the belief that in accordance with the Convention of the rights of the
child’s articles 3, 4, 5, 6, 18 (3), 23-24, 27 (1)-(3) and 33, and the General
Comments 5 (2003), 4 (2003), and 13 (2013) and as exemplified in other
countries, that the state should:
Ensure that the diagnosis of children for ADHD and other similar diagnoses is
done based on evidence of the disorder and in the best interest of that child, that
research on the root causes of such disorders is carried out, and the
recommended treatment is based on these findings of that child, that
psychotropic drugs are prescribed as a measure of last resort and only after an
individualized assessment of the best interests of the child, that children and their
parents are properly informed about the possible side effects of medical
 CCHR REPORT: ADHD LABELING AND TREATMENT OF CHILDREN IN JAPAN 12

treatments and about non-medical alternatives, and that support is provided to

initiatives aimed at the development of non-medical treatments for such
disorders.
The state party further should ensure that experts and others advising or
consulted in the process of implementing treatment and formulating guidelines
are not having conflicts of interest and are independent of the pharmaceutical
industry.
The current guidelines should be reviewed by independent experts. And the
process is to be transparent.

Citizens Commission on Human Rights

The Citizens Commission on Human Rights (CCHR) was established in 1969 by the
Church of Scientology and co-founded by professor of psychiatry, Dr. Thomas
Szasz to investigate and expose psychiatric violations of human rights, and to
clean up the field of mental healing.
While CCHR doesn’t provide medical or legal advice, it works closely with and
supports medical doctors and medical practice. A key CCHR focus is psychiatry’s
fraudulent use of subjective “diagnoses” that lack any scientific or medical merit,
but which are used to reap financial benefits in the billions, mostly from the
taxpayers or insurance carriers. Based on these false diagnoses, psychiatrists
justify and prescribe life-damaging treatments, including mind-altering drugs,
which mask a person’s underlying difficulties and prevent his or her recovery.
CCHR endorses the Convention on the Rights of the Child and specifically have
been campaigning for the rights of the child throughout the world for more than
a decade in which CCHR is active as an NGO.
Today, CCHR has more than 140 chapters in over 31 countries. Its board of
advisers, called Commissioners, includes doctors, lawyers, educators, artists,
businessmen, and civil and human rights representatives.

Noriyasu Yoneda Torsten Hjelmar

CCHR Japan CCHR Europe22

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