Child and Consumer Advocates Urge Federal Trade Commission to Investigate and Bring Action Against Google for Excessive and Deceptive Advertising Directed at Children

A coalition of prominent children's and consumer advocacy groups filed a complaint with the Federal Trade Commission (FTC) today requesting an investigation of Google, charging the company with unfair and deceptive practices in connection with its new YouTube Kids app. The complaint details a number of the app's features that take advantage of children's developmental vulnerabilities and violate long-standing media and advertising safeguards that protect children viewing television. 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." As the complaint points out, however, the company 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 important policies include (1) a prohibition against the host of a children's program from delivering commercial messages; (2) strict time limits on the amount of advertising any children's program can include; (3) the prohibition of program-length commercials; and (4) 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."

The complaint also charges that Google is violating its own advertising policies for YouTube Kids. For example, while the company promises that food and beverage ads will not appear on the app, advertising and promotions for junk food are prominently featured throughout.

"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."

"There is nothing 'child friendly' about an app that obliterates long-standing principles designed to protect kids from commercialism," added Josh Golin, Associate Director of Campaign for a Commercial-Free Childhood. "YouTube Kids exploits children's developmental vulnerabilities by delivering a steady stream of advertising that masquerades as programming. 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."

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."

"In today's digital era, children deserve effective safeguards that will protect them regardless of the 'screen' they use," explained Jeff Chester, Executive Director of the Center for Digital Democracy. "In addition to ensuring that Google stops its illegal and irresponsible behavior to children on YouTube Kids, new policies will be required to address the growing arsenal of powerful digital marketing and targeting practices that are shaping contemporary children's media culture - on mobile phones, social media, gaming devices, and online video platforms."

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.

A copy of the group's letter to the FTC is available at www.democraticmedia.org and www.commercialfreechildhood.org/youtubekids.