Mr. Casey Baseel of SoraNews24 reported on March 12, 2022, that Tokyo’s Metropolitan Board of Education revised certain long-standing dress code policies in Tokyo’s municipal high schools. First, the Board abolished rules requiring students with naturally non-black hair to dye their hair black – which was in effect at seven high schools. Second, the Board abolished underwear color requirements – which was in effect at thirteen high schools. Third, it abolished prohibitions of the “two block” undercut hair style, which was in effect at 24 high schools. Fourth and finally, the Board required 95 high schools to write their dress codes with specificity instead of using vague phrases such as that students must dress “in an appropriate manner for a high school student.”

Photo of Tokyo Metropolitan Nishi High School in the day. English: Abasaa日本語: あばさー, Public domain, via Wikimedia Commons
Photo of Tokyo Metropolitan Nishi High School. Note that I chose this photo for illustrative purposes. I know nothing about this particular high school or its dress code policies.
Photo Credit: English: Abasaa日本語: あばさー, Public domain, via Wikimedia Commons.

Because I covered a story last year about a Japanese student with naturally brown hair having been forced to dye her hair black to satisfy the dress code requirements of a school in Osaka Prefecture, I decided to cover the abolition of similar controversial rules in Tokyo.

Article Overview

Below, I will first cover the hair color issue – which I wrote about last year with respect to a controversy in Osaka Prefecture. After covering the new hair color policies and revisiting my past content on the issue, I will examine separately the other three dress code changes announced by the Tokyo Board with an eye toward examining how they advance the natural objectives and purposes of a school dress code.

Revisiting the Hair Color Controversies for Japanese Students With Naturally Brown Hair

Government schools in Japan have a reputation for encouraging conformity in dress. For that reason, they often have dress codes. Many of these dress codes prohibit dying one’s own hair. Rules about hair color are neither unusual nor unheard of in dress codes. However, some Japanese school boards created an odd system that required certain students to dye their hair to comply with a rule that generally prohibited hair dying.

The vast majority of students in Japanese public schools are ethnically Japanese. The vast majority of ethnically Japanese people have naturally black hair. However, there are exceptions – a small number of ethnically Japanese people have naturally brown hair. One might think that if a Japanese student has brown hair, he or she would be, like students with black hair, precluded from dying it. Mr. Baseel explained in a February 2021 article, which I in turn covered here at The New Leaf Journal:

Ostensibly, school dress codes are supposed to be about eliminating distractions, and so it’s common for Japanese schools to prohibit students from dying their hair. However, problems can occur if schools rigidly assume that no one dying their hair will always result in everyone having the same hair color.

One ethnically Japanese Osaka student with naturally brown hair was forced to dye her hair black. That is, she was required to dye her hair in order to conform to a dress code that usually prohibits hair dying.

There is a tension underlying the cases wherein a school forces a student with naturally non-black hair to dye his or her hair black. The dress code rules regarding hair color at these schools have two objectives. Firstly, they seek to impose conformity – that is, the expectation is that because an overwhelming majority of their students are ethnically Japanese and an overwhelming majority of ethnically Japanese students have naturally black hair, the expected result of hair dying prohibitions is that (almost) all of the ethnically Japanese students should have black hair. Secondly, the dress codes seek to regulate conduct – in this case changing one’s own hair color. When an ethnically Japanese student starts with dark brown hair instead of black hair, one of the prerogatives of the hair color dress code rules must give way.

When a school declines to countenance an exception to the hair color rules for an ethnically Japanese student with dark brown hair, it is effectively prioritizing an outcome-based interpretation of the rule. That is, the school is expressing that its primary concern is that its ethnically Japanese students all have black hair (I will venture that foreign students or students who obviously have at least one non-Japanese parent may be more likely to obtain an exception than someone like the girl in the Osaka case). The prohibition on hair dying accomplishes this objective in 99-percent of cases. In cases where the prohibition on hair dying does not accomplish the objective, the school discards the hair dying prohibition in order to accomplish the conformity objective.

Tokyo’s Hair Color Policy Change

The case that I wrote about in February 2021 came from Osaka Prefecture. Thus, the story about the Tokyo Metropolitan Board of Education changing its hair color rules affects different schools. Nevertheless, the issues and policies involved are substantially similar – as Mr. Baseel noted in linking to his 2021 report in the new article. Mr. Baseel explained the effect of the Tokyo policy change:

Spring is the start of the academic year in Japan, and during the 2021 school year seven pubic high schools in Tokyo still required students with natural non-black hair to dye it black. For the 2022 school year that’s about to start, though, the rule has been completely abolished, and no longer remains in effect at any municipal high school.

To begin, it is worth noting that a very small minority of Tokyo’s public high schools had rules on the books requiring students with naturally non-black hair to dye their hair black. Mr. Baseel reported that this policy was in place at seven high schools. While I do not know how many public high schools exist in the Tokyo Metropolitan Area – which is the most populous metropolitan area in the world – Mr. Baseel noted that a separate rule change relating to the wording of dress codes affected 95 high schools. However, we cannot rule out that some schools beyond the seven that had an express rule requiring naturally brown-haired students to dye their hair black may have imposed similar rules on a case-by-case basis, such as what was reported about Osaka. I do not know whether this was the case – but it is worth noting that it is possible that the rule change may have a broader effect than the small number of Tokyo schools directly affected would indicate.

Photo of Tokyo Metropolitan Takashima High School in the day.  English: Abasaa日本語: あばさー, Public domain, via Wikimedia Commons.
Photo of Tokyo Metropolitan Takashima High School. Note that this photo is here for decorative purposes. I do not know anything about this particular Tokyo high school or its dress code policies.
Photo Credit: English: Abasaa日本語: あばさー, Public domain, via Wikimedia Commons.

Mr. Baseel explained that notwithstanding the rule change, dying one’s hair is still generally prohibited in most Tokyo high schools. Moreover, at certain schools, ethnically Japanese students with naturally non-black hair may still have to jump through hoops to obtain a dispensation from dress code authorities:

[S]chools no longer forcing students with natural non-black hair to dye it black does not mean that students who do have naturally black hair are now allowed to dye it another color. Because of that, 20 high schools in 2022 will still have systems in place where students with naturally non-black hair submit a jigi shomeisho, or “certificate of natural hair” when not dying their hair black. Even this number is down from 55 in 2021, though, and overall Tokyo teens are going to enjoy greater freedoms as their schools treat them a little more like grownups.

Even after the policy change, 20 high schools in Tokyo will still require students with non-black hair to submit a certificate establishing that their hair is naturally not black. Presumably, absent such a certificate, the schools could still require a student with non-black hair to dye his or her hair black under the presumption that the student had dyed his or her hair from black. It is worth noting that in the Osaka case I discussed last year and in the previous section of this article, the school’s position was that the student, who stated that her hair was naturally brown, had actually dyed her hair brown. Thus, students with naturally non-black hair (as well as students who say they have naturally non-black hair) may still face some complications at a limited subset of Tokyo high schools. (Let us not contemplate the cases where a student with naturally non-black hair dyed his or her hair before seeking a dispensation from the policy…). Interestingly, however, Mr. Baseel noted that in 2021, 55 Tokyo high schools required proof of natural hair color in such cases, meaning that the number that have the requirement in 2022 dropped by about 64-percent.

My Take: Equality Over Equity Hair Color Codes

As a general matter, I do not oppose school dress codes, nor do I think that prohibiting students from dying their hair is presumptively unreasonable. Whether a dress code requires a specific uniform or instead sets narrow standards for what constitutes acceptable attire in the school setting, one central reason for having a dress code is to ensure that all of the students dress modestly and appropriately. Allowing for hair dying can, absent narrow parameters, allow students to circumvent the purpose of the dress code.

With respect to hair color rules, the issue in Japan is different than it would be in the United States, which has a far more ethnically diverse student population. While not all students in Japanese public schools have two ethnically Japanese parents, the vast majority do. It is unusual for someone with two Japanese parents to have non-black hair, and I will venture (without a specific study) that most people who have one Japanese parent are more likely than not to have black hair as well.

However, having granted the facts of biology and hair color inheritance, Japanese schools that required students with brown hair to dye their hair black – a policy that was more likely to be wielded against ethnically Japanese students than anyone else – lost the plot of the dress code.

In modern Western parlance, Japanese schools that required students with naturally brown hair to dye their hair black focused on equity (equal outcomes) over equality in conduct. The point of a dress code is ultimately to regulate behavior and decorum. It is the regulation on behavior that achieves good outcomes. The behavior-based focus on the dress code provides that the emphasis of hair color dress code rules should be to prohibit students from changing their hair color. Instead, some Japanese schools opted for an equity-based focus, meaning that they demanded that all students end up in the same place (having black hair) regardless of whether they actually have black hair. In so doing, they singled out a small number of Japanese students who, through no fault of their own, had brown hair, and forced them to engage in conduct (dying their hair) that was ordinarily proscribed.

A dress code must provide for a single set of rules for all students. That is not to say that every student can necessarily dress exactly the same way without running afoul of the dress code (for example – students have different builds and weights which affect how clothes fit – and a cut which may satisfy a dress code in case A may violate it in case B; rules are different for boys and girls, etc.), but the fundamental requirements should be the same. The dress code should state its objectives and provide for policies that are in accord with those objectives. With respect to hair color, a restriction on coloring one’s hair should be just that. The rule should be that students must either (A) attend school with their natural hair color or (B) return their hair to something as close to their natural hair color as is possible if their hair was colored.

As a general matter, I do not have a problem with schools that prohibit coloring one’s hair to require proof of natural hair color. In the context of Japanese schools, it is not presumptively unreasonable to request proof in cases where a student deviates from the almost universal norm – separate and apart from whether this is the best policy. However, whether a policy is fair and beneficial depends on its implementation. Firstly, schools must not question students publicly – the issue should be handled in private with the student and his or her parents. Secondly, schools must be clear, transparent, and ultimately reasonable about what constitutes proof of natural hair color. As we saw in the allegations that were reported in the Osaka case, the proof of natural hair color requirement can be abused – and the consequences of abuse are both damaging and also unfair to students who are being honest about their natural hair color.

Taken together, my view of the Tokyo rule changes – as they are reported in the SoraNews24 article – is positive. The rule changes regarding hair color accomplish two things. Firstly, they ensure that the hair color rules focus on conduct instead of hair color outcomes – which in turn better achieve the purposes of a dress code by regulating student behavior in a fair way. Secondly, they avoid punishing Japanese students (and perhaps foreign students and ethnically non-Japanese students generally – depending on how the previous rules were implemented) for the crime of not having the same hair color as the majority of Japanese people. So long as these new rules are adhered to and the limited number of schools that require proof of having naturally non-black hair implement that policy fairly – the hair color dress code changes appear to be a good step forward.

A Look Back At My Iroha Isshiki Hair Color Article

Shortly after I published my piece on the Osaka story in 2021, I wrote an article about an anime character who was described as having naturally brown hair.

The unwieldy-named My Youth Romantic Comedy Is Wrong, As I Expected is a popular lite novel series in Japan that has also been published in English (commonly known as Oregairu for short). It was also adapted into an anime series, which is called the unwieldy My Teen Romantic Comedy SNAFU in English (see my section on it in recommended anime series from 2011-2020).

One of the main characters in the second half of the series is named Iroha Isshiki. She was portrayed in both the novels and also the anime as having chestnut-brown hair. It had already been referenced in the anime – which is set in an ordinary modern Japanese high school in Chiba Prefecture in a world like our own with no magic or superpowers – that many of the students in the school dyed their hair. For that reason, I assumed without giving it too much thought that Iroha was portrayed as having brown hair for artistic license (something we discovered was the case with another character) or that she, like some of the other girls in the school, had dyed her hair.

For that reason, I was surprised to read in the novel that the protagonist, Hachiman Hikigaya, expressly stated that her hair appeared to be naturally brown.

Screen capture of Hachiman Hikigaya and Iroha Isshiki of Oregairu having a conversation together on a train in episode 10 of the second season.
Hachiman (left) and Iroha (right) seen together in episode 10 of the second season of My Teen Romantic Comedy SNAFU. I took this clip from the episode on Crunchyroll.

That line caught my attention when I read it before reading about the Osaka story because I did not recall another example from media wherein it was expressly noted that a Japanese character in a real-world setting had naturally brown hair. It was also interesting in light of the fact that the series provides no indication that Iroha had a non-Japanese parent.

Shortly after I published my article on the Osaka story, I wrote a general article about hair color in anime that ended up focusing specifically on Iroha. One thing led to another, and there is now a growing series of articles on hair color in Japanese anime and games, including one where it is explicitly noted that a Japanese high school character in a different show set in Hokkaido had black hair while some of her classmates dyed their hair.

I would be curious to know what inspired Wataru Watari, the author of Oregairu, to make a point of noting that Iroha had naturally brown hair. In light of the fact that some of the series is inspired by his own high school experiences, perhaps she is based on someone he knew. In any event, the anime hair color series will continue – but it is interesting to occasionally check on real-world Japan.

Assessing the Other Rule Changes

Mr. Bassel’s article noted that the Tokyo Metropolitan Board of Education implemented several other dress code directives in addition to the new hair color rules. I will offer my take on the other policy changes below.

Underwear Rules

Talk about an attention-grabbing headline.

Mr. Baseel explained the rule change:

[T]he 13 high schools that had rules specifying what color of underwear students had to wear will now all leave that choice up to students. The logic behind such rules was that the required colors would prevent students’ underwear from being visible through their uniforms, but the sounder logic that as long as the underwear isn’t visible, it’s nobody’s business what color it is has won out.

I agree with this rule change entirely. In following a school dress code in Japan (or likely anywhere else, for that matter), one’s underwear should not be visible. Think of it in this way. Let us assume arguendo that a school only allows students to wear white undergarments. If the student’s white undergarments are visible, he or she is almost certainly violating the dress code – absent some accident – notwithstanding that his or her undergarments are the correct color. I imagine that one purpose of the undergarment color rules is to ensure that undergarments do not show through parts of the uniform such as white shirts. However, that requirement can be upheld (“make sure your undergarments do not show through your shirt”) without color rules for those who otherwise satisfy the requirement. If a student’s undergarments are showing (either externally or through his or her uniform), the school can address that dress code violation with the student in a responsible manner. Depending on one’s skin tone, the color of undergarment best suited to this task may vary.

Regulating underwear colors as a general matter for students whose underwear is not visible (because said students are wearing their uniforms properly) invites abuse from overzealous administrators and ensuing general unpleasantness.

Hair-Style Rules

The Board removed restrictions on a certain hair style. Mr. Baseel explained:

Getting back to hair regulations, the 24 schools that had previously banned the “two block” undercut style, in which boys shave their hair short on the sides and grow it out on top, have gotten rid of the rule. Though the two block has been associated with juvenile delinquents, it’s also become a pretty popular mainstream fashion look that, as we can attest, doesn’t immediately lead one to a life of crime.

At least one SoraNews24 writer was strongly opposed to the “two block” undercut hairstyle ban, and to be sure, the Board’s prior argument that it is too closely associated with criminality was not entirely convincing.

With that being said, the flashy hair style could certainly not be described as conservative. I dare say it is flasher than hair dyed brown. While far be it from me to say that the Board erred in lifting the ban on the mohawk-esque hair style, I would probably decline to permit it were I to write a school dress code. I would certainly not permit it if I were working with a dress code that did not allow students to dye their hair innocuous colors that exist in nature.

The author of the article opposing the ban talked to a conscientious adult who had the hair style. Of course, adults in Japan may dye their hair to whatever color they want. The issue is not how self-sufficient adults comport themselves, it is how students in schools do. That the hair style is fine for adults in the real world and is not actually indicative of crime does not necessarily means it is a natural fit in an otherwise strict high school dress code.

Void For Vagueness

The final rule change affected more Tokyo high schools than the aforementioned changes. Mr. Baseel explained:

Numerically, the biggest change is a semantic one, but still one students will be happy to see. In a review of school rules by the board, 95 high schools were found to have vague phrases such as “in an appropriate manner for a high school student” in their conduct policies and directions. Those have now been changed to better address the specific issue using less arbitrary language.

In short, the Board appears to have declared certain phrases in dress codes void for vagueness.

I do not think that a phrase such as “in an appropriate matter for a high school student” is inherently unsuitable for a dress code. Whether it is amenable or not to a well-conceived dress code depends on its purpose in the overall dress code.

A dress code should articulate its purposes and objectives. As a general matter, one purpose of a dress code is to ensure that students dress in an appropriate matter comporting with the objectives of a high school classroom. If a general phrase is presented as articulating the purpose of a dress code – I have no issue with it.

Problems may arise, however, if general statements are then enforced in an ad hoc manner as specific rules. That is, the phrase “in an appropriate matter for a high school student” should not be a rule in and of itself. It should be a sort of preamble that describes the purpose of the specific dress code rules that follow. Interpreting a phrase that articulates a broad idea or objective as a specific rule would result in problems for two reasons. Firstly, school administrators may interpret and enforce the general phrase inconsistently. Secondly, it does not provide clear and distinct guidance to students and parents.

To use a American example, consider the preamble to the U.S. Constitution:

We the People of the United States, in Order to form a more perfect Union, establish Justice, insure domestic Tranquility, provide for the common defense, promote the general Welfare, and secure the Blessings of Liberty to ourselves and our Posterity, do ordain and establish this Constitution for the United States of America.

I examined the phrase “a more perfect union” specifically in a September 2020 article. The Preamble, unlike what follows in the Constitution, is not a law. It establishes the purpose of the Constitution. Justice John Marshall Harlan explained the purpose of the preamble in a decision of the Supreme Court of the United States:

Although that Preamble indicates the general purposes for which the people ordained and established the Constitution, it has never been regarded as the source of any substantive power conferred on the Government of the United States or on any of its Departments. Such powers embrace only those expressly granted in the body of the Constitution and such as may be implied from those so granted. Although, therefore, one of the declared objects of the Constitution was to secure the blessings of liberty to all under the sovereign jurisdiction and authority of the United States, no power can be exerted to that end by the United States unless, apart from the Preamble, it be found in some express delegation of power or in some power to be properly implied therefrom.

Jacobson v. Massachusetts, 197 U.S. 11, 22 (1905)

That is, forming a more perfect union, along with the other objectives stated in the Preamble, is the purpose of the Constitution. However, the objectives in the Preamble do not confer or take away powers from the Federal government or the States. The beautiful language of the preamble serves far better as a statement of purpose than as substantive law.

Returning from the eloquent writing of Governeur Morris (author of the preamble) and Justice Harlan to Japanese high schools, the same idea applies in a much quainter manner to the phrase “in an appropriate manner for a high school student.” The phrase is altogether fitting and proper for explaining the purpose of a dress code. It is entirely inadequate for serving as the dress code itself.


Having covered hair color issues in Japanese high schools last year and written about how hair color and styles are presented in several anime series, I was interested to read about the new policy changes in Tokyo, which affect a large percentage of Japanese high school students given how big Tokyo is. The hair color change seems positive, provided that it is implemented correctly. I had some mixed views on the other changes – but the overall impression is positive and I hope that they lead to schools enforcing dress code policies consistently and fairly while providing clear guidance to students and achieving the general purposes of school dress codes.