Popular Channel Ryan ToysReview Under Fire After Being Accused Of Violating FTC Law
Popular YouTube channel Ryan ToysReview is under fire after being accused of misleading young viewers about which videos actually feature paid advertisements. The channel, which features a mashup of unboxings, toy reviews, and family-friend adventures was reported to the Federal Trade Commission (FTC) by watchdog group Truth In Advertising (TINA) for deceptive practices targeting children.
The complaint against Ryan’s channel, which was filed on August 28, 2019, alleged that they “deceptively promote[s] a multitude of products to millions of preschool-aged children in violation of FTC law.”
The channel is run by seven-year-old Ryan and his parents, Shion Guan, 31, and Kieu Loan Guan, 35. The family is also known to use the pseudonym Kaji as their public surname. Since its launch, Ryan ToysReview has gained over 31 billion views and signed endorsements with companies like Hardee’s/Carl’s Jr., Colgate, and Chuck E. Cheese.
TINA provided multiple examples of the channel’s deceptive marketing practices, including screenshots of two videos uploaded within nine days of each other. The first video, titled “Ryan Pretend Play Pizza Delivery Cooking Playhouse!!!” showed Ryan pretending to cook and serve pizza. Just nine days later, he uploaded another video titled “Ryan’s Drive Thru Pretend Play With Hardee’s New Star Pal Toys!!!” The videos featured similar formats and titles, but as TINA noted, “one is sponsored and one (presumably) is not.” The watchdog group observed that there was no disclosure to indicate that Hardee’s was “teaming up with kids’ entertainment studio pocket.watch and Ryan’s World® for a first-of-its-kind partnership as YouTube creators continue to transform the toy industry.”
Ryan ToysReview blurs the distinction between advertising and organic content for its intended audience.
—Truth In Advertising
They observed that the channel does not always disclose whether it’s content was sponsored, and often times if it did, the disclosures were found to be “inadequate”, with voiceovers or flashing text lasting less than two seconds. Federal law requires “clear and conspicuous” disclosures that consumers are able to notice, process, and understand. TINA’s complaint explains that the voiceover disclaimers provided by the channel are not in Ryan’s voice and play right after a pre-roll advertisement making it unlikely that his preschool-aged audience would take note of it.
In a statement released by Ryan’s father, Shion Guan, the family publicly contested the filing of the complaint by stating, “We 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.”
TINA revealed that they decided to file the complaint against Ryan ToysReview after being contacted by Democratic Representative Anna Eshoo about her work regarding deceptive social media marketing geared toward children.
This isn’t the first time Ryan ToysReview was criticized for not adequately disclosing sponsored content. In 2017, they were the subject of a Children’s Advertising Review Unit (CARU) investigation. The investigation found sponsored content for Walmart and Mattel, among other companies, and concluded that children could “reasonably believe that all the Ryan ToysReview videos, including sponsored ones, were independent and unbiased unless there was a clear disclosure indicating otherwise.” In the end, they recommended the channel include “an audible disclosure at the beginning of each video” to clearly identify it as advertising, however, they have consistently failed to comply with CARU’s recommendation.
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