YouTube Kids Faces Further FTC Complaints Related To Junk Food Ads Targeting Young Children

Consumer watchdog groups announced today they’ve filed additional complaints with the FTC over the advertising content in the YouTube Kids application. The complains this time focus on how the app allows food and drink advertisers to violate the self-regulatory pledges they made as members of the Children’s Food and Beverage Advertising Initiative (CFBAI). That program’s aim is to shift the advertising mix to promote healthier dietary choices in ads aimed at those under the age of 12.

According to the new complaints, a number of big-name brand advertisers including Coca-Cola, Oreo, Kellogg, General Mills and more, have broken their pledges to not advertise their products – including Coke, Coke Zero, Pop-Tarts, pizza and Oreo cookies, for example – to young children.

YouTube Kids, YouTube’s first app aimed at the preschool set, was initially thought of as a relief for parents who wanted an easier way to keep small children from stumbling upon YouTube’s more adult fare. But the app, which is effectively this generation’s version of TV in terms of its presence in the lives of children, has faced controversy and complaints from consumer advocacy groups, and even U.S. Senators, concerned about the app’s content and its advertising.

Now, two new complaints related to advertising have been filed by the Campaign for a Commercial-Free Childhood (CCFC) and the Center for Digital Democracy (CDD) – watchdog organizations that have been targeting YouTube Kids since its debut for not doing enough to protect children from adult content, as well as for what they refer to as “deceptive ads.”


Young children simply don’t have the cognitive ability to distinguish between ads and programming, and YouTube Kids takes advantage of that fact, the groups believe.

On television, FCC regulations prohibit some of the activity that’s permitted in the YouTube Kids application, like host selling, or not following guidelines regarding time limits on how often ads can be shown.

Meanwhile, YouTube’s advertising guidelines only apply to paid ads – the 30 or 60-second videos that are shown before the selected video. But as YouTube admits in its app’s disclaimer, kids will be exposed to “commercial content” from YouTube creators. But this content is not considered a paid ad. That means it doesn’t have to follow any of YouTube’s more stringent guidelines, which also state that food and beverage ads are prohibited, regardless of nutrition content. 

As the advocacy groups previously noted in their prior FTC complaints, the commercial content found on YouTube Kids today includes things like actual TV commercials, company-produced promotional videos, host-selling videos, and product placements.

The investigation related to deceptive ads is still underway, Josh Golin, CCFC’s Executive Director, tells us.

Coca-Cola, Hershey, Mars & More Cited As Top Offenders

These new complaints, the groups explain, are calling on the FTC to broaden its investigation to also examine Google’s relationship with multichannel video programmers; food, beverage and toy companies; YouTube advertising and “unboxing” video partners; and companies that specialize in “influencer” and product placement marketing on YouTube.

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Specifically, the CCFC and CDD say in one complaint they found evidence that 17 food and beverage manufacturers are violating the pledges they made as members of the above-mentioned health-focused initiative, CFBAI.

For example, Coca-Cola had pledged to not market any beverages to children under 12, but the groups found 47 TV commercials and 11 longer promotional videos for Coke and Coke Zero on YouTube Kids.

Mondelez International had pledged not to market Oreos to children, but the CCFC and CDD found 31 TV commercials and 21 product placements for Oreos on YouTube Kids. One involves YouTube star Evan (“EvanTubeHD”), whose content is distributed by Disney-owned Maker Studios, trying to guess 12 different Oreo flavors in an 11-minute video.

Products made by companies who promised not to advertise to kids under 12 included sugary snacks like Nutella (Ferrero USA), Reese’s and Hershey’s Kisses (Hershey), Snickers (Mars, Inc.), Toll House Cookies (Nestle USA, Inc.), and more. Meanwhile, products from companies that said they would only advertise items meeting CFBAI nutrition criteria included Burger King pushing its Whoppers and fries; Kraft selling Velveeta; plus products from McDonald’s; as well as Oreos; Doritos; Swiss Miss cocoa; General Mills’ Totino’s Pizza, Kellogg’s Pop-Tarts and others.

Some videos were straight-up TV ads, others promotional videos and many more were clear, but unlabeled, product placements.

YouTube Kids Screenshot

“The Commission should investigate why Google’s algorithms aren’t configured to keep junk food marketing off of YouTube Kids, and hold food and beverage companies accountable for violating their pledges not to target their most unhealthy products to children,” says Golin.

The second complaint documents a number of videos that appear to result from paid relationships between advertisers, YouTube creators, and intermediaries (those that specialize in connecting advertisers with talent). The relationships are not disclosed on YouTube, and the groups want these business relationships investigated further.

Today, YouTube’s ad policy for YouTube Kids is that it will remove videos where the creator has disclosed a paid product placement or endorsement using YouTube’s tools. But clearly, relying on the creator community to self-police is not effective, as these FTC complaints indicate.

“We believe FTC now has more than enough documentation to hold Google accountable for YouTube Kids’ unfair and deceptive practices,” says Golin.

The detailed complaints are embedded below:

CFBAI complaint against YouTube Kids

YouTube Kids Supplemental complaint