Speed, Access, and Ethics in a Bold Regulatory Experiment
In the global quest to turn the promise of regenerating damaged tissues and organs into reality, Japan made a daring decision: to completely rewrite the rulebook.
Japan introduced a groundbreaking regulatory framework that would allow patients to access cutting-edge cell and gene therapies much earlier than ever before.
This "Japanese experiment" has since fueled a rapid expansion of treatments, pioneering discoveries, and a vibrant debate on how to balance innovation with patient protection.
At the heart of Japan's approach is a unique two-track system, designed to navigate the complex journey from laboratory research to a patient's bedside 1 .
This is the pathway for manufacturers seeking full market authorization. It allows for conditional approval of a therapy, enabling it to enter the market while more data on its efficacy is collected 1 5 .
This pathway is for physicians in clinical practice. It allows them to use unapproved cell and gene therapies, provided their plans are reviewed and approved by a government-accredited ethics committee 1 .
Includes therapies derived from pluripotent stem cells (like iPS cells), anything that is genetically modified, and all allogeneic (donor-derived) cells. These face the most stringent review 1 .
Covers autologous (a patient's own) cells that are expanded in culture or used for a non-homologous purpose (i.e., used for a different function than they had in the body) 1 .
Reserved for autologous cells that are minimally manipulated and used for a homologous purpose. These have the least stringent approval process 1 .
A cornerstone of the PMD Act is its conditional approval system. If a therapy demonstrates promise and a confirmed safety profile in early trials, it can be approved for the market for a limited time—typically seven years 1 7 .
"This system enables faster patient access to novel therapies by permitting approval based on surrogate endpoints," notes the JSRM 1 .
During this period, the manufacturer must conduct post-marketing surveillance to gather more data and confirm the treatment's efficacy.
Therapy demonstrates promise and confirmed safety profile
Approved for market for up to 7 years with requirement to inform patients that efficacy is not yet proven
Manufacturer collects more data on efficacy during conditional period
Therapy either receives full approval or is withdrawn from market if efficacy not confirmed
Companies must inform patients that efficacy is not yet proven, and patients are expected to participate in ongoing data collection. If the treatment fails to prove effective by the end of the conditional period, its authorization is withdrawn, as was the case with Terumo's HeartSheet for heart failure 1 .
While the regulatory framework facilitates the journey from lab to clinic, Japanese scientists continue to push the boundaries of what is scientifically possible.
In 2022, researchers at Tokyo's Keio University, led by Professor Hideyuki Okano, began a pioneering clinical study on four patients with spinal cord injuries 3 .
The goal was to assess the safety of a new approach and look for signs of restored function.
Researchers started with specialized adult cells and reprogrammed them into induced pluripotent stem (iPS) cells—a juvenile, pluripotent state.
These iPS cells were then prompted to develop into specific cells of the neural stem.
In an operation, more than two million of these iPS-derived cells were injected directly into the damaged spinal cord of each patient.
The patients were closely monitored for a year to track their recovery and any potential adverse events 3 .
The primary goal was to study safety, and on that front, the results were encouraging. "No serious adverse event was observed for all four cases after a year of monitoring," the university reported 3 .
Even more remarkably, the motor function scores for two of the four patients improved after the operation. Public broadcaster NHK reported that one elderly male patient was able to stand without support and had started practicing walking again 3 .
This study is monumental as it is the world's first clinical study of its kind for spinal cord injury. While the team is cautious, the improved motor function in two patients provides a crucial proof of concept.
| Research Tool | Function in the Experiment |
|---|---|
| Induced Pluripotent Stem (iPS) Cells | The starting material; can be differentiated into any cell type in the body, avoiding ethical issues of embryonic stem cells. |
| Neural Differentiation Factors | Chemical signals that direct iPS cells to mature into neural stem cells and other cells of the nervous system. |
| Temperature-Responsive Culture Dishes | A technology invented in Japan that allows for the creation of intact cell sheets for transplantation without enzymatic damage. |
| Immunosuppressants | Often required in allogeneic (donor-derived) cell therapies to prevent the patient's immune system from rejecting the new cells. |
Japan's accelerated pathway has not been without controversy.
One significant challenge is the potential for predatory clinics to exploit the regulatory loopholes. The case of the Seijikai Fukuoka MSC Clinic highlights this issue.
In 2025, the clinic was issued a business improvement order by the health ministry for offering unproven stem cell treatments for conditions like cancer and hardened arteries without submitting its plans to the authorities 7 .
Such clinics capitalize on the hype around regenerative medicine, making inflated claims to desperate patients.
Furthermore, the system has been criticized for its limited capacity to rigorously review efficacy and potential conflicts of interest within the accredited committees that approve ASRM therapies 1 5 .
The low number of reported adverse events has also raised questions about the thoroughness of safety monitoring 1 .
These issues highlight the inherent tension in a framework that tries to govern both high-stakes industry development and private clinical practice simultaneously.
| Therapy/Product | Condition Treated | Status & Notes |
|---|---|---|
| iPS-derived retinal pigment cells | Age-related macular degeneration | One of the first iPS cell therapies to be commercially explored. |
| Skeletal muscle-derived cardiomyocyte sheets | Heart failure | An example of pioneering cell sheet engineering developed in Japan. |
| Autologous cultured cartilage | Cartilage defects | Originally regulated as a medical device before the PMD Act. |
| Temcell (allogeneic mesenchymal stem cells) | Graft-versus-host disease | An early example of a marketed stem cell product. |
Japan's now decade-long "experiment" in regenerative medicine regulation has proven one thing for certain: it is possible to dramatically accelerate the clinical application of groundbreaking science.
The country's two-track system has created an environment where innovation can thrive, yielding world-first treatments and solidifying its position as a global leader.
However, this speed comes with trade-offs. The challenges of ensuring rigorous oversight, preventing exploitation, and gathering robust efficacy data in a post-market setting are very real.
As regulators in the U.S. and elsewhere consider reforming their own frameworks, Japan's experience serves as a crucial case study 1 . It offers a compelling model of accelerated access while simultaneously providing a cautionary tale about the absolute necessity of building strong, transparent, and vigilant safeguards for patients.
The ultimate goal for the global community is to find that delicate balance, ensuring that the revolutionary promise of regenerative medicine is fulfilled both quickly and safely.