Above all, their complaint alleges that YouTube Kids is exposing them to advertising masquerading as ordinary programming in a variety of ways.
Among other things, the letter to the FTC claims that YouTube Kids mixes advertising and programming in ways that deceive children, for example with “branded channels” maintained by brands like McDonald’s, Barbie and Fisher-Price, which the letter claims are “little more than program-length commercials.”
The letter also raises questions about YouTube Kids’ user-generated segments featuring toys, candy and other products, which the advocates warn may violate the FTC’s guidelines governing endorsements.
The letter also claims that YouTube Kids violates a number of standards applied to broadcast and cable TV programming targeting kids, including prohibiting hosts from delivering commercial messages, time limits on total commercial content and prohibition of product placements and “embedded” ads.
It argues: “The fact that children are viewing the videos on a tablet or smartphone screen instead of on a television screen does not make it any less unfair and deceptive.”
The coalition behind the letter includes groups like Consumer Watchdog, the Center for Digital Democracy, Campaign for a Commercial-Free Childhood, American Academy of Child and Adolescent Psychiatry, Center for Science in the Public Interest, Children Now, Consumer Federation of America, Consumers Union, Corporate Accountability International and Public Citizen.
The advocates called on expert opinion to back up their complaints, for example, citing Dale Kunkel, a professor of communication at the University of Arizona, who was quoted as saying: “YouTube Kids is the most hyper-commercialized media environment for children I have ever seen. Many of these advertising tactics are considered illegal on television, and it’s sad to see Google trying to get away with using them in digital media.”