PhotoConsumer groups are calling for a federal investigation of Google, saying its new YouTube Kids app preys upon children's vulnerability and violates longstanding media practices intended to safeguard children.

“There is nothing 'child friendly' about an app that obliterates long-standing principles designed to protect kids from commercialism,” said Josh Golin, Associate Director of Campaign for a Commercial-Free Childhood, one of the groups filing a complaint with the Federal Trade Commission.

“YouTube Kids exploits children’s developmental vulnerabilities by delivering a steady stream of advertising that masquerades as programming," Golin said. "Furthermore, YouTube Kids' advertising policy is incredibly deceptive. To cite just one example, Google claims it doesn't accept food and beverage ads but McDonald's actually has its own channel and the 'content' includes actual Happy Meal commercials.”

Among the specific practices identified in the complaint are:

  • Intermixing advertising and programming in ways that deceive young children, who, unlike adults, lack the cognitive ability to distinguish between the two;
  • Featuring numerous “branded channels” for McDonald’s, Barbie, Fisher-Price, and other companies, which are little more than program-length commercials;
  • Distributing so-called “user-generated” segments that feature toys, candy, and other products without disclosing the business relationships that many of the producers of these videos have with the manufacturers of the products, a likely violation of the FTC’s Endorsement Guidelines.

When it launched the YouTube Kids app in February, Google described it as “the first Google product built from the ground up with little ones in mind.”

Safeguards scrapped

But the complaint says Google appears to have ignored not only the scientific research on children’s developmental limitations, but also the well-established system of advertising safeguards that has been in place on both broadcast and cable television for decades.

Those safeguards include

  • a prohibition against the host of a children’s program from delivering commercial messages;
  • strict time limits on the amount of advertising any children’s program can include;
  • the prohibition of program-length commercials; and
  • the banning of “product placements” or “embedded advertisements.”

Such “blending of children’s programming content with advertising material on television,” the group’s complaint declares, “has long been prohibited because it is unfair and deceptive to children. The fact that children are viewing the videos on a tablet or smart phone screen instead of on a television screen does not make it any less unfair and deceptive.” 

"Hyper-commercialized"

“YouTube Kids is the most hyper-commercialized media environment for children I have ever seen,” commented Dale Kunkel, Professor of Communication, University of Arizona. “Many of these advertising tactics are considered illegal on television, and it's sad to see Google trying to get away with using them in digital media.”

Angela J. Campbell of the Institute for Public Representation at Georgetown Law, who serves as counsel to the coalition, called on the FTC to "investigate whether Disney and other marketers are providing secret financial incentives for the creation of videos showing off their products. The FTC’s Endorsement Guides require disclosure of any such relationships so that consumers will not be misled." 

Organizations signing the complaint include: the Center for Digital Democracy, Campaign for a Commercial-Free Childhood, American Academy of Child and Adolescent Psychiatry, Center for Science in the Public Interest, Children Now, Consumer Federation of America, Consumer Watchdog, and Public Citizen.


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