Ryan ToysReview Under Fire for Allegedly Being 'Deceptive' with Paid Ads Targeting Preschoolers

TINA's executive director told Today Parents that preschool-age kids "don't have the intellectual capacity to distinguish when they're being pitched to"

Ryan ToysReview — a popular preschool-targeted YouTube channel boasting over 20 million subscribers, featuring a 7-year-old boy named Ryan Kaji playing with and reviewing playthings — is in hot water with Truth in Advertising.

In a complaint filed to the Federal Trade Commission on Aug. 28, the nonprofit group (known as TINA) slammed the channel, alleging that it “deceptively promotes a multitude of products to millions of preschool-aged children in violation of FTC law.”

“Ryan ToysReview’s sponsored content is presented in a manner that misleadingly blurs the distinction between advertising and organic content for its intended audience,” the letter reads, giving examples of “deceptive marketing” like ads for Carl’s Jr., Nickelodeon and Chuck E. Cheese that they alleged contain either no disclosures or “inadequate” ones (e.g., written) that children watching the videos would not naturally pick up on.

“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,” the complaint states of a March 2019 advertisement for Teenage Mutant Ninja Turtles.

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Ryan ToysReview
Ryan ToysReview.

One of the complaint’s authors, TINA Executive Director Bonnie Patten, spoke to Today Parents about the letter, saying, “Organic content, sponsored content — it’s really all the same to a preschooler.”

“They just don’t have the intellectual capacity to distinguish when they’re being pitched to and when there’s a child playing with a toy because he likes that toy,” she added.

In the complaint, Patten and TINA Legal Director Laura Smith wrote, “when a YouTube video directed to children under the age of 5 mixes advertising with program content, as Ryan ToysReview videos frequently do, the preschool audience is unable to understand or even identify the difference between marketing material and organic content, even when there is a verbal indicator that attempts to identify the marketing content.”

“Preschoolers can’t read,” Patten told Today Parents. “[Ryan ToysReview] can’t use this sort of native advertising to market to preschoolers.”

Ryan ToysReview
Ryan Toysreview/Youtube

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In an interview with The New York Times, the executive director at Campaign for a Commercial-Free Childhood, Josh Golin, said, “A 5-year-old isn’t going to understand that Ryan’s talking about the toys because Target is paying him to talk about the toys.”

“There may be some disclosure, but disclosure isn’t meaningful to a child that young,” he added.

A statement from Ryan’s dad Shion Kaji to both Today Parents and the Times insisted that the family prioritizes their viewers’ safety and “strictly follow all platforms’ terms of service and all existing laws and regulations, including advertising disclosure requirements.”

“As the streaming space continues to quickly grow and evolve, we support efforts by lawmakers, industry representatives, and regulators such as the FTC to continuously evaluate and update existing guidelines and lay new ground rules to protect both viewers and creators,” Kaji added in the statement.

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