Boston (November 22, 2019) – Senator Edward J. Markey (D-Mass.) today sent a letter to Google demanding answers about YouTube’s advertising policies for content that is directed to children. YouTube, which Google owns, operates both the main YouTube platform and YouTube Kids. YouTube’s parental guide indicates that YouTube is not for children under the age of 13 and characterizes YouTube Kids as a destination for children ages 12 and under. However, vast numbers of child users watch videos on YouTube itself, and there is a wide range of child-focused content available for children on YouTube’s main platform. 


Notably, many of the advertising policies that protect children on the YouTube Kids platform do not appear to apply to content that is directed to children on YouTube’s main platform. These rules prohibit videos from including product placement, influencer unboxing videos, and other types of commercial content that are inappropriate or harmful to children. In his letter, Senator Markey calls out this gap in YouTube’s protections for children and seeks answers about YouTube’s policies. 


“The access that children have to YouTube carries with it a corporate obligation to institute and enforce policies that protect the wellbeing of these young users,” writes Senator Markey, a member of the Senate Commerce, Science and Transportation Committee, in his letter to CEO Sundar Pichai. “Unfortunately, it appears there are large gaps in YouTube’s advertising policies, which raise concerns about your commitment to safeguarding children from inappropriate advertising.”


A copy of Senator Markey’s letter can be found HERE.


In his letter, Senator Markey asks for responses to questions that include:

  • Will the YouTube Kids advertising policies that restrict content in paid advertising on YouTube Kids apply to content that is directed to children on YouTube? These policies include prohibitions on sexually suggestive, violent, and dangerous content, as well as misleading or deceptive claims or incitements to purchase.
  • Will your company apply to content that is directed to children on YouTube the same YouTube Kids advertising policies that restrict product categories?  
  • The advertising policy for YouTube Kids also includes advertisement-formatting requirements. Will these requirements, such as maximum length (15-20 seconds for non-skippable ads and 60 seconds for skippable ads), and the requirement that ads are clearly identifiable as ads, apply to content that is directed to children on YouTube?
  • Will content that is directed to children on YouTube be completely free of targeted advertising?
  • Please describe in detail YouTube’s system for ensuring compliance with advertising rules on YouTube Kids. Has YouTube conducted research into the prevalence of advertising rule violations on YouTube Kids? If not, why not? If so, please share YouTube’s findings. 


In June, Senator Markey wrote to the FTC expressing concern that YouTube has violated Children’s Online Privacy Protection Act (COPPA) and urging the Commission to include a series of new privacy safeguards that YouTube should implement as part of any potential consent decree stemming from a Commission investigation into children’s privacy on YouTube.  


In November 2018, Senator Markey asked FTC Chairman Joseph Simons specifically about YouTube’s potential violation of COPPA.