New York, NY –  Oct. 18, 2017  – The Children’s Advertising Review Unit has determined that certain content featured on at “Ryan Toys Review,” a popular YouTube Channel aimed at children, is advertising and that such content should be clearly identified as advertising to the child audience.

Further, CARU has determined that inappropriate advertising running adjacent to RTR videos – including advertising for wine and an R-rated film – should be discontinued. The company has agreed to comply with CARU’s recommendations.

CARU, an investigative unit of the advertising industry’s system of self-regulation, monitors websites and apps for compliance with CARU’s Self-Regulatory Program for Children’s Advertising, including guidelines on privacy protection, as well as with the federal Children’s Online Privacy Protection Act. CARU is administered by the Council of Better Business Bureaus.

The advertising at issue came to CARU’s through CARU’s routine monitoring of advertising directed to children.

RTR  is a YouTube channel that self-describes as directed to young children and their families.   The channel debuted in 2015 and now has more than 8 million subscribers and more than 15 billion views worldwide.

RTR videos feature 6-year-old Ryan shopping for toys, playing with toys, receiving toy packages to unbox, playing games and eating kids’ meals from fast food restaurants.  Many of the videos also feature Ryan’s father and recently his twin baby sisters and his mother.  Most RTR videos are filmed by his mother in their home.

Following CARU’s initial inquiry, RTR said it had reached out to the YouTube advertising platform to prevent further advertisements for alcohol or other inappropriate products from appearing in pre-roll or other advertising on RTR in the future.

With regard to advertising disclosures in the videos, RTR asserted that there were only a few instances where it received any financial incentive or products for review and contended that it provides both visual and audio disclosures of such relationships.

In this case, CARU first determined that sponsored videos on RTR contain advertising messages and are a form of advertising.  CARU then considered whether that fact is clear and adequately disclosed to the child audience as required by CARU’s guidelines and the Federal Trade Commission.

The guidelines, as CARU noted in its decision, recognize that children may have difficulty distinguishing between editorial content and advertising and state that advertising should not be presented in a manner that blurs this distinction in a way that would be misleading to children. To determine what messages are conveyed to children in advertising, CARU first looks to consumer-perception evidence.  Where, as in this case, no such evidence is supplied, CARU routinely steps into the shoes of the child-targeted audience and uses its experienced judgment to determine the reasonable messages conveyed.

In all of the videos on RTR, Ryan displays the same sense of excitement a typical child would about the products featured, whether they are sponsored or not.  The potential confusion between sponsored and unsponsored videos is further underscored by the fact that a majority of the videos start with pre-roll ads.  Because children may easily recognize these pre-roll videos as commercials they may be even less likely to suspect that further advertisements are contained within the RTR videos, CARU said.

CARU concluded that the commercial nature of the videos was not adequately disclosed and that children could reasonably believe that all the RTR posts, including sponsored ones, were independent unless there was a clear disclosure indicating otherwise.

Following its review, CARU recommended RTR include an audio disclosure at the beginning of each sponsored video, identifying the video as advertising.

RTR, in its advertiser’s statement, said that “in light of CARU’s recent recommendations, we will implement procedures to enhance disclosures of connections to brand marketers in accordance with CARU’s voluntary guidelines in this continually expanding field.”