Last month, we and our friends at Center for Digital Democracy filed comments with the Federal Trade Commission asking them once again to effectively address the troubling rise of influencer marketing targeted at children.
Five years ago, we requested that the FTC formally investigate the deceptive practice of kid-targeted influencer marketing. The FTC didn’t act, and since then, influencers and “kidfluencers” – social media and YouTube “celebrities” known for promoting sponsored products in between posts about their lives – have exploded in popularity (and raked in sponsorship revenue) across the internet, all while further blurring the lines between entertainment and advertising.
Often, influencer “content” is indistinguishable from influencer advertising, even for adults. On YouTube, channels like Ryan’s World and EvanTubeHD promote toys and their product lines in unboxing videos, and other influencers post clips telling where to buy outfits like theirs. Junk food marketers like BurgerKing and Doritos target kids and teens with commercialized dance “challenges” on TikTok. On Twitter, artists promoting Frozen 2 were even instructed by Disney to hide that their art was sponsored.
Ryan Kaji and his father promoting Ryan’s World branded toys in a recent YouTube video.
While the FTC Endorsement Guides require influencers to clearly and legibly disclose sponsored content, this screenshot shows an almost unreadable disclosure.
While the FTC Endorsement Guides do require influencers to disclose whether they’ve been compensated by the companies they are promoting, few actually do so, as the FTC rarely holds influencers accountable for failing to disclose. In fact, the FTC has taken no action against child-targeting influencers or their sponsors for failing to follow the Guides, despite how common violations are!
And while being more explicit about influencer sponsorship might help parents recognize commercial content, research shows that children do not understand disclosures. Kids are already extremely vulnerable to traditional forms of advertising, like TV commercials; when there’s no separation between programming and advertising, children are unlikely to even understand they are being marketed to.
But clear disclosure or not, influencer marketing isn’t good for kids. The whole point of influencer marketing is to leverage the “relationship” between influencers and kids to get children to want stuff. The materialistic values influencers promote have been shown to negatively impact people’s wellbeing. For families, the effects of influencer marketing can be even more pronounced. When children watch unboxing videos, they are more likely to nag their parents for products and throw a tantrum if the answer is no than when they watch regular commercials. Deliberately encouraging tantrums shouldn’t be part of marketers’ playbook!
Last year, popular kidfluencer channel EvanTubeHD posted a video on YouTube called “THANOS IS HERE!!! Countdown to Avengers Endgame! Giant Thanos on Throne!” The video was posted just a day before the release of the much-hyped and widely advertised Marvel movie Avengers Endgame.
The 10-minute clip features Evan and his dad excitedly discussing the upcoming movie and what will happen in it, then unwrapping and assembling an exclusive figurine of Thanos, a character from the film. The video is chock-full of Marvel promo. In addition to the Thanos figurine, the video flashes the official Avengers movie logo, features another smaller Thanos toy, and Evan’s dad wears a Thor shirt (another character from the film).
And yet, despite the fact that this video is an ad in everything but name, it’s promoted as entertainment that is appropriate for kids!
It’s clear the FTC needs to enforce their Endorsement Guides. But to truly protect kids, they need to go further – that’s why we’re asking them to ban influencer marketing targeted to kids under 13.
For many influencers’ followers, they feel a strong bond to the influencer, largely thanks to certain techniques used in posts and videos. Influencers show their followers their homes in YouTube videos, “introduce” their friends and families, share personal stories and moments, and sometimes even communicate with followers directly over social media. By sharing so much about themselves, influencers create a parasocial relationship with their followers – a one-sided feeling of admiration on the part of followers. For many young fans, this bond makes them feel as if they are friends with influencers like Ryan Kaji, and trust them like a friend, too. And it’s because of this trust that kids are even more vulnerable to influencer advertising – and exactly why companies are so eager for social media celebrities to put their products in front of young audiences.
On kids’ TV programs, there are regulations to stop marketers from taking advantage of children’s developmental vulnerabilities by blurring the lines between programming and ads: product placement, “program-length commercials,” and host-selling (when TV characters or hosts promote a product during the show) are all banned by the FCC, and have been for nearly 30 years. But regulation of internet and mobile media for children lags far behind children’s television and as a result, manipulative influencer marketing aimed at children has exploded online.
Frankly, that just doesn’t make sense. A child deserves the same protections whether they are watching Nickelodeon or YouTube. Influencer marketing aimed at kids is, well, just plain gross. It’s manipulative. It’s not good for families.
Our children deserve for their trust to be respected, not taken advantage of by marketers and influencers. They deserve role models that encourage their curiosity and imagination, not materialistic values. Kids deserve more – and it’s time the FTC showed up for them.