In a recent decision, the Children’s Advertising Review Unit (CARU) called for more prominent disclosures of ad content on a child-directed YouTube channel.

The case involved Ryan Toys Review (RTR), a channel that debuted in 2015 and self-describes as being directed to young children and their families. The videos feature six-year-old Ryan shopping for toys, playing with toys, receiving toy packages to unbox, playing games and eating kids’ meals from fast food restaurants. The channel—which also features Ryan’s family members and is typically filmed in their home—has more than eight million subscribers and north of 15 billion views.

After reviewing videos on the channel, CARU expressed concern that the sponsored videos constituted advertising but lacked adequate disclosures. Some of the videos contained written disclosures (such as “Thank you Walmart for sponsoring this video”), others had audio and written statements (“Travel, promotional and other considerations were provided by Mattel”), and some only had written disclosures that appeared in the comments section below the videos on the channel page (“Thanks for sponsoring!” or “Free products and paid support”). Other videos had no disclosures at all.

The self-regulatory body first determined that the sponsored videos on the RTR channel are a form of advertising.

“These videos are paid commercial messages whose purpose is to induce the sale of a product and/or persuade the audience of the value of a product or brand,” CARU wrote. “For instance, in some of the sponsored videos, Ryan’s mother informs viewers the sale price of the toys and where a consumer can purchase the items. In another video, Ryan’s mother tells the child audience that RTR is going to a major retailer to find the ‘top toys chosen by kids,’ after which Ryan shouts, ‘Kids like me!’ Later in the video, he states that the store sent him the toys he wanted. At the end of the video, after playing with all of the toys, Ryan tells his peers that ‘you can buy all these toys at Walmart.’”

However, the commercial nature of the videos was not clear to the child audience and was inadequately disclosed, CARU found, as “children could reasonably believe that there was no difference between the sponsored and unsponsored content and … children viewing the sponsored videos may not understand that they were in fact advertising.”

By virtue of their immaturity, inexperience and lack of cognitive skills, younger children may not understand “the persuasive intent of advertising” and may not even understand that they are being subject to advertising, CARU said. Traditional television advertising has standard cues (such as ad breaks) that help children recognize that what they are seeing is not entertainment, but something else.

“However, sponsored videos on YouTube and other video-sharing websites, which integrate the sponsored content into the entertainment, do not have similarly consistent methods to alert children to the presence of advertising content,” according to the decision. “Without such standardized disclosures, sponsored videos, like those on RTR, may give the impression that they are unbiased and unaffiliated opinions.”

Going forward, CARU recommended that RTR disclose to children that the sponsored videos featuring a brand’s products are advertising. “This should be done by placing a clear and prominent audio disclosure stating that the sponsored videos are advertising, at a minimum, at the start of the video,” the self-regulatory body advised, using simple, unambiguous language such as “ad” or “advertisement” in a standardized format.

In its review, CARU also found advertisements that appeared before videos that were inappropriate for the child audience (an ad for wine, for example, as well one for an R-rated film). RTR reached out to YouTube to prevent incidents of inappropriate products appearing on the channel in the future.

To read CARU’s press release about the case, click here.

Why it matters: It is “imperative to adequately and consistently disclose the presence of advertising to children who are less sophisticated than adults,” CARU emphasized, particularly with regard to advertising hosted by a “social media celebrity” like six-year-old Ryan. “These types of advertisements may have an even stronger influence than typical child-directed advertisements because the sponsored messages are being delivered by a trusted source to a loyal audience.”