Someone told on 8-year-old YouTube king’s channel

Not Toyin’ Around

Remember Ryan, from Ryan ToysReview? When last we met Ryan, we were stunned by his reach as an influencer. At the tender age of 7, Ryan, along with his mother and father, was the owner and star of one of the world’s most popular YouTube channels. At the time (2017 to be exact), his frenetic, hyper-cut, colorful review videos had earned him somewhere around 9.4 million subscribers and more than 16 billion – that’s billion – total views.

What a difference two years makes. Today, Ryan and his fam have captured the eyes of more than 21 million subscribers, and their videos have been viewed 31 billion times, more than any other channel on YouTube. One source estimates that he earned $22 million between June 2017 and June 2018.

That Was Then

Back then, we reported that Ryan’s channel was peripherally involved in a Children’s Advertising Review Unit investigation. One of Ryan’s partners, WhatNot Toys, was accused of soliciting information from consumers without complying with the applicable legal requirements for the youngsters who were likely to visit its site.

In today’s edition, Ryan is the main player in a complaint filed with the Federal Trade Commission by Truth in Advertising, Inc. ((TINA). The accusation? Ryan is breaking the law, TINA claims, by failing to disclose material connections with brands that are appearing in his videos.

TINA cites a video with the understated title of “Ryan’s Drive Thru Pretend Play with Hardee’s New Star Pals Toys!!!” TINA maintains that this video, launched days after a similarly food-themed video that lacked brand endorsement, is aimed squarely at preschoolers who are unable to assess the relationship between “organic” content and advertisement. “While adults may be able to spot the ad,” the watchdog explains in its case summary, “[T]hey are not the target audience . . . children under the age of five are. And for them, it’s impossible to discern the difference, even if the Hardee’s video disclosed the burger joint’s partnership with Ryan ToysReview, which it does not.”

The complaint cites a passel of other videos for similar infractions involving well-known brands like Chuck-E-Cheese and Nickelodeon.

The Takeaway

TINA references another CARU investigation from 2017, in which the group “found that sponsored content . . . was not adequately disclosed,” on Ryan’s channel. “CARU concluded that children could reasonably believe that all the Ryan ToysReview videos, including sponsored ones, were independent and unbiased unless there was a clear disclosure indicating otherwise.”

TINA notes that CARU recommended that Ryan’s videos feature an audible disclosure at the beginning of each video to identify sponsored content, and that the channel ignored their guidance.

And then, interestingly, TINA takes CARU to task: “[B]ut the recommendation itself was, unfortunately, flawed because it was not based on data regarding the channel’s target audience’s age or consumer perception. . . . Had CARU obtained data on the specific age of Ryan ToysReview’s target audience, as well as the consumer perception of this demographic, it would undoubtedly have concluded that even an audible disclosure . . . does not clarify the content for its target audience or eradicate the deception present in such videos.”

We’ll see where this complaint goes; remember, it’s essentially just a request for the FTC to take a look. But if you’re advertising products and services to kids, it might pay to remember that children under 13 are not all the same when it comes to making subtle distinctions about content. TINA is adding a further shading to the under-13 demographic: youngsters under the age of 5 or so, who cannot differentiate advertising from “regular” content at all, and who therefore deserve extra consideration.