The US Federal Trade Commission (FTC) has received a complaint about highly popular, toy-unboxing YouTube channel Ryan ToysReview. 

US non-profit organisation Truth in Advertising has filed a complaint with the FTC in regards to the channel's content, claiming that it, "deceptively promotes a multitude of products to millions of preschool-aged children." 

The channel, which currently has over 21 million subscribers, features Ryan and his family playing with, reviewing and unboxing toys along with some vlog-style lifestyle content. 

The channel has also featured paid sponsored content from an array of toy companies and Truth in Advertising suggests that the sponsored content is not clearly distinguished enough as an advertisement when compared to the channel's other videos. 

Truth in Advertising goes further to claim that while the channel is disclosing when content is sponsored, the disclosures are not sufficient enough to distinguish the videos as an advertisement to what it believes is Ryan's preschool audience. 

"Even when Ryan ToysReview does use disclosures, they are inadequate.

"By way of example, in a March 2019 ad a woman’s voice quickly states "this is an ad..." at the beginning of the lengthy video while the same statement is flashed on the top of the screen.

"The voiceover disclosure is not in Ryan’s voice, is stated at the beginning of the video before Ryan’s playing begins, is completed in less than two seconds, and is played immediately after a pre-roll advertisement, making it highly unlikely that Ryan’s preschool fans will notice the audible disclosure.

"As for the printed disclosure at the top of the screen, if Ryan’s audience could (1) read, and (2) understand what the phrase "this is an ad..." means, then such a disclosure might be sufficient," Truth in Advertising said.

In its closing statement, Truth in Advertising encouraged the FTC to review the channel.

"A preschooler’s cognitive ability to identify and understand that they are being presented with marketing materials is generally lacking.

"In fact, it is for precisely this reason that the Federal Communications Commission has a longstanding policy that prohibits product placements in television programs produced and broadcast to children 12 years old and under.

"Given these data, there can be no support for the proposition that a preschool YouTube channel, such as Ryan ToysReview, can present its target audience with native advertising videos and expect that any disclosure will clearly and conspicuously inform this young and vulnerable population that they are being lobbed a sales pitch. 

"Accordingly, urges the FTC to review the marketing on Ryan ToysReview’s YouTube channel and take appropriate enforcement action." 

In response to the complaint, Shion Kaji - parent to Ryan - told BuzzFeed News in a statement that the family, "strictly follow[s] all platforms’ terms of service and all existing laws and regulations, including advertising disclosure requirements."

The FTC has not made any indication as yet that it will review the complaint or the channel. 


To familiarise yourself with Australian ad standards in regards to advertising to children, click here. 

To familiarise yourself with Australian ad standards in regards to clearly distinguishable advertising, click here. 

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