Consumer watchdog groups have filed a complaint to the Federal Trade Commission (FTC), accusing Google of blurring the line between ads and original content in its YouTube Kids app. The complaint alleges that Google has broken a number of broadcasting rules, including mixing "commercial and other content in ways that are deceptive and unfair to children" and hosting videos from individuals with undisclosed links to products they are endorsing.
For example, the complaint says that unboxing videos on the app violate the FTC’s "Guide Concerning the Use of Testimonials in Advertising." This requires that individuals endorsing products on TV disclose any connections with the manufacturer that "might materially affect the weight or credibility of the endorsement." The popular unboxing genre features individuals opening newly-bought toys, clothes, and electronics, and was the subject of 20 million searches last year.
"Many of the [unboxing] videos on YouTube Kids appear to be user-generated. Some, however, have undisclosed relationships with product manufacturers," reads the complaint. "For example, the Disney-owned Maker Studios has agreements with five popular YouTube channels — DisneyCarToys, HobbyKidsTV, TheEngineeringFamily, ToysReviewToys, and AllToyCollector... All five YouTube channels affiliated with Disney’s Maker Studios are also available on YouTube Kids."
"There's no disclosure of who actually owns those channels."
"We want Google to pull all of its unboxing videos from the app," Jeff Chester, director of the Center for Digital Democracy, one of the signatories on the complaint, told the San Jose Mercury News. "There's no disclosure of who actually owns those channels. They're an ad, in essence, for toys."
The complaint also notes that videos and advertising on YouTube Kids are played in a continuous stream, counter to the TV rules that require a five-second "bumper" between ads and shows. "Selecting My Little Pony brings up four options," read the complaint. "Two of the four options are labeled 'TV Commercial.' The other two are identified as 'TV Clip' but are actually promotions for the My Little Pony program."
The YouTube Kids app in a tablet.
And while Google’s own guidelines for the app prohibit advertising "related to consumable food and drinks," the complaint points out that YouTube Kids hosts a channel created by McDonald’s to explain the provenance of its chicken nuggets, beef burgers, and other fast food items.
"children do not understand that the entire channel is advertising.""[Sponsored channels] take advantage of children because they do not understand that the entire channel is actually advertising," says the complaint. Although the five-minute clips do include a small notice marking them as "promotional consideration provided by McDonald’s," the complaint alleges that this also constitutes deceptive marketing — not to children, but to parents.
The complaint has been filed to the FTC by Georgetown Law’s Institute for Public Representation, and is signed by a number of groups including the Campaign for a Commercial-Free Childhood, Consumers Union, Children Now, and the American Academy of Child and Adolescent Psychiatry. The director of the Center for Digital Democracy described the complaint as "the opening shot" in "a battle for the hearts and minds and pocketbooks of America's kids in the digital age."
YouTube, meanwhile, has issued a statement saying: "When developing YouTube Kids we consulted with numerous partners and child advocacy and privacy groups. We are always open to feedback on ways to improve the app.”