Dive Brief:

• Nonprofit organization Truth in Advertising (TINA) has filed a deceptive advertising complaint with the Federal Trade Commission (FTC) against the popular Ryan ToysReview channel on YouTube, according to materials shared with Marketing Dive.
• The channel offers toy reviews that it says are "for kids by a kid." TINA contends that Ryan ToysReview deceives children who can't tell "the difference between advertising and organic content."
• Over a seven-month investigation that ended in July, TINA analyzed every video on the channel. It found that 90% of the videos referred to at least one product for children under the age of five.

Dive Insight:

As so-called "kidfluencers" like Ryan ToysReview proliferate, they can be expected to face the type of scrutiny and criticism aimed at the rest of influencers, meaning brands need to pay close attention to who they are partnering with. Ryan ToysReview, with more than 21 million subscribers, is a YouTube leader and reportedly the most viewed YouTube channel ever. It centers around Ryan, who began opening and playing with toys on the channel in 2015, when he was three. With these kind of viewership numbers, it's not surprising the channel has attracted a variety of sponsors who offer products for the videos, including Hardee's and Nickelodeon.

Scrutiny by watchdog groups and regulators is likely to continue to be a problem for digital content whose target audience is preschoolers who, presumably can't tell the difference between editorial content and ads. TV has guidelines against this kind of hidden advertising for children, but YouTube content faces fewer restrictions. The latest complaint comes as YouTube and its parent Google recently agreed to pay $170 million to settle allegations around YouTube's collection of children's personal information without proper consent. 

Last year, TINA took aim at Diageo, accusing the alcoholic beverage giant of running an extensive, noncompliant influencer campaign promoting its Ciroc label. Previously, DJ Khaled backed off of social media posts that featured liquor brands following complaints from TINA. The Kardashians and Jenners also were targets of TINA for allegedly not properly disclosing commercial relationships with brands they post about on social media.

TINA's latest complaint with the FTC isn't the first effort to bring attention to the hidden infomercials lurking in this genre of "unboxing" videos and amateur critiques. In January, the public prosecutor's office in São Paulo, Brazil, announced it was suing YouTube owner Google for "abusive advertising practices toward children" in unboxing videos. If successful, this latest complaint could lead to new standards for product reviews and "unboxing" videos on YouTube when they target young viewers.