Watchdog group Truth in Advertising has filed a complaint with the Federal Trade Commission, accusing the YouTube channel of deceiving children through “sponsored videos that often have the look and feel of organic content.”
Hosted by seven year-old Ryan Kaji, YouTube channel Ryan ToysReview has built an audience of 21m since 2015, while the channel has racked up more than 30b views. Truth in Advertising found that nearly 90% of the videos have included at least one paid product recommendation aimed at pre-school children, who the watchdog argues are too young to distinguish between a commercial and a review.
“Ryan ToysReview’s sponsored content is presented in a manner that misleadingly blurs the distinction between advertising and organic content for its intended audience,” states the complaint. “According to the FTC, when such a blending of content occurs, any material connection between an endorser and the seller of the advertised product must be clearly and conspicuously disclosed in a manner that will be easily understood by the intended audience.”
Many children do not recognize advertising until they are eight or nine years old, according to the Campaign for a Commercial-Free Childhood. “A five year-old isn’t going to understand that Ryan’s talking about the toys because Target is paying him to talk about the toys,” said a spokesperson. “There may be some disclosure, but disclosure isn’t meaningful to a child that young.”
The organization also points out that the Federal Communications Commission “has a longstanding policy that prohibits product placements in television programs produced and broadcast to children 12 years old and under.”
In a statement, Ryan’s father Shion Kaji responded: “The well-being of our viewers is always the top priority for us, and we strictly follow all platforms’ terms of service and all existing laws and regulations, including advertising disclosure requirements. As the streaming space continues to quickly grow and evolve, we support efforts by lawmakers, industry representatives and regulators such as the FTC to continuously evaluate and update existing guidelines and lay new ground rules to protect both viewers and creators.”
Many toy companies and retailers have pursued endorsements with kid influencers like Ryan ToysReview, although the FTC has repeatedly warned influencers to clearly disclose their relationships to brands in their social media posts. However, watchdog groups believe that, without enforcement, the agency’s warnings have had little effect. Last month, the commission was asked to investigate Ryan ToysReview in regard to two commercials for the fast-food chain Carl’s Jr. that were posted without disclosing that they were ads.
The success of Ryan ToysReview has spawned a cable and online series: Ryan’s Mystery Playdate and a range of Ryan’s World products including toys. The toy industry will be watching developments with interest.