Exhibit 5.1

November 7, 2024

To:

MEDIROM Healthcare Technologies Inc.
3-1 Daiba 2-chome, Minato-ku, Tokyo, Japan

Re: MEDIROM Healthcare Technologies Inc. / American Depositary Shares

Dear Sir / Madam:

We act as Japanese special counsel for MEDIROM Healthcare Technologies Inc. (the “Company”), a corporation incorporated under the laws of Japan, in connection with the underwritten public offering and sale by the Company of certain new common stock shares of the Company (the “New Shares,” and the common stock shares of the Company in general, the “Shares”) in the form of American Depositary Shares (the “ADSs,”), for an aggregate of up to 3,450,000 Shares in the form of ADSs (including up to 450,000 Shares issuable upon exercise by the underwriter of their over-allotment option), as described in the Company’s Registration Statement on Form F-1 (including all exhibits thereto and as amended from time to time, the “Registration Statement”), as filed by the Company with the Securities and Exchange Commission in accordance with the Securities Act of 1933, as amended (the “Securities Act”). The New Shares represented by ADSs are to be sold by the Company pursuant to an underwriting agreement (the “Underwriting Agreement”) by and between the Company and ThinkEquity LLC (the “Representative”), the form of which is filed as Exhibit 1.1 to the Registration Statement. The Company is also registering warrants to purchase up to 172,500 Shares to be issued to the underwriter as additional compensation pursuant to the Underwriting Agreement (the “Representative Warrant”), and up to an aggregate of 172,500 Shares represented by ADSs issuable upon exercise of the Representative’s Warrants (the “Representative Warrant Shares”; collectively with the New Shares represented by ADSs and the Representative’s Warrants, the “Securities”).

For the purposes of this opinion letter, we have examined originals and/or photostatic copies of such documents as we have deemed relevant. In conducting our examination, we have assumed, without independent verification, the legitimacy of all signatures, the legal capacity of each party thereto, the authenticity of all the documents submitted to us as originals, the conformity to the originals of all the documents submitted to us, and the accuracy and completeness of all records made available to us by the Company. In addition, in rendering this opinion letter, we have assumed that the Securities will be offered in the manner and on the terms and conditions described or referred to in the Registration Statement.

NAYUTA Partners■ WWW.NAYUTA-LAW.COM

14F, Tokyo Square Garden■ 3-1-1 Kyobashi, Chuo-ku, Tokyo ■ Phone +81 (0)50 3692 4135 ■ Fax +81 (0)50 3512 3987

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This opinion letter is limited solely to the matters expressly set forth herein. Our opinions expressed herein are limited only to the laws of Japan, and we do not purport to express or imply any opinion with respect to the applicability or effect of the laws of any other jurisdiction. We express no opinion concerning, and assume no responsibility as to, laws or judicial decisions related to any federal laws, rules or regulations, including but not limited to any federal securities laws, rules or regulations, or any state securities or “blue sky” laws, rules or regulations.

Based upon and subject to the foregoing, and having regard to legal considerations and other information we have deemed relevant, we are of the view that (i) the New Shares have been duly and validly authorized, and that when the New Shares are issued and delivered following application for subscription thereof and payment in full to the Company of all considerations required therefor, in the manner and on the terms and conditions described in the Registration Statement and the relevant resolutions of the meetings of the board of directors of the Company and in accordance with the proceedings described therein, all the New Shares will be duly and validly issued, fully paid and non-assessable; and (ii) the Representative’s Warrant Shares have been duly authorized for issuance and, when issued and sold by the Company and delivered by the Company and upon valid exercise thereof and against receipt of the exercise price therefor, in accordance with and in the manner described in the Registration Statement, the Underwriting Agreement, the Representative’s Warrants and the relevant resolutions of the meetings of the board of directors of the Company, will be validly issued, fully paid and non-assessable.

We hereby consent to the reference to our firm’s name under the caption “Legal Matters” in the Prospectus included in the Registration Statement and the use of this opinion letter as an exhibit to the Registration Statement. Despite such consent, we do not admit that we come within the category of persons where consent is required under Section 7 of the Securities Act or the rules and regulations of the Securities and Exchange Commission.

Yours sincerely,

/s/ NAYUTA Partners Law Office

NAYUTA Partners■ WWW.NAYUTA-LAW.COM