2023

Protecting Kids from Stealth Advertising in

Digital Media 

S T A F F P E R S P E C T I V E | S E P T E M B E R 2 0 2 3 

Preface 

by Samuel Levine 

Director, Bureau of Consumer Protection 

Last year, the FTC held a workshop, Protecting Kids from Stealth Advertising in Digital Media, 

aimed at exploring the techniques being used to advertise to children digitally and online, and 

what measures should be implemented to protect them from manipulation and other harms. This 

workshop highlighted research showing that many young consumers do not have the skills or 

cognitive defenses to identify or sufficiently evaluate blurred advertising, potentially leading to 

physical, psychological, financial, privacy, and other harms. This and other findings are detailed 

further in the following Staff Perspective and Recommendations, which I urge marketers and 

other stakeholders to read carefully. 

Although our October 2022 Event, and the below Staff Perspective and Recommendations, focus 

specifically on blurred advertising to kids in digital media, it is critical that we recognize the 

broader context in which this issue arises. There are many new and emerging trends for children 

online, many of which lead to, or exacerbate, the harms associated with blurred advertising. We 

now live in a digital world where kids spend a significant portion of their free (and school) time 

online. They find themselves in immersive environments like gaming platforms, virtual reality, 

and social media, many of which use techniques to keep them engaged longer and more 

frequently than ever before; they interact with influencers, avatars, and emerging forms of 

artificial intelligence, forming parasocial relationships that blur the lines between friends and 

strangers, people and computers; they are the subjects of intrusive data collection, often used to 

target them with marketing or content; they are presented with hundreds of ads a day, a number 

that increases as kids spend more time online; they are lured into making purchases or turning 

over data through the use of dark patterns; and they are particularly vulnerable to fraud that 

pervades these digital environments. In addition, as the U.S. Surgeon General recently noted, 

there are growing concerns about screen addiction and mental health issues associated with 

increased screen time. 

In this moment, it is clear that inaction is not an option. Nor is it an option to place the burden 

entirely on parents to protect their children from these harms. Although it may have been 

reasonable at one time to expect a parent to monitor kids’ media and advertising exposure (e.g., 

via a television in the living room for an hour a day), we no longer live in that world. Kids are 

spending many hours a day online on very small screens that they can take anywhere. It is 

unrealistic to think parents can sufficiently monitor this type of digital media use, especially in 

households with working parents, single parents, parents who do not speak English as their first 

language, or those who face other challenges or time constraints. And even if parents could 

magically monitor the vast majority of their kids’ time online, it would be nearly impossible for 

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Protecting Kids from Stealth Advertising in Digital Media | Staff Perspective 

them to keep up with the ever-changing technology and digital landscape. In fact, many parents 

are unfamiliar with the apps their children use and how they use them. 

In the FTC’s recent COPPA cases, including U.S. v. Epic Games, Inc., No. 5:22-CV-00518-BO 

(W.D.N.C. Feb. 7, 2023), we are doing what we can to take the burden off parents, and instead 

place the onus on operators to ensure that children’s data is protected. That same approach 

should guide our work with respect to blurred advertising. Creators, advertisers, and platforms 

must take responsibility for preventing and addressing the harms associated with blurred 

advertising. And this responsibility is about more than additional disclosures. Disclosures, while 

necessary, are not the silver bullet. As experts have made clear, there is no silver bullet. 

In the following Staff Perspective and Recommendations, FTC Staff addresses the key concerns 

raised by blurred advertising to kids and recommends a multi-pronged approach to addressing 

them. The serious concerns that emerge in the research and through our workshop make clear 

that protecting children online requires a comprehensive approach. 

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Introduction 

On October 19, 2022, the Federal Trade Commission (“FTC”) hosted Protecting Kids from 

Stealth Advertising in Digital Media (“FTC Kids Advertising Event,” “Event,” or “workshop”), 

about the blending of advertising and content and how it affects kids, including teens.1

 In recent 

years, we have seen more advertising to kids embedded in surrounding content, particularly in 

the digital space: social media influencers advertise products and services, kids create unboxing 

videos, and advertisements are woven into online games and virtual reality worlds, among other 

examples. 

In July 2022, the FTC published a Federal Register notice discussing comments it received in 

response to its review of its Guides Concerning the Use of Endorsements and Testimonials in 

Advertising (“the Endorsement Guides”).2 In the notice, the FTC recognized that “it is difficult 

for children—especially younger children—to discern ads from entertainment or other content in 

the digital environment where the lines are blurred much more than in traditional ‘linear’ media, 

like television.”3

 FTC Staff sought information and expertise that could assist in the development 

of specific guidance or best practices with respect to blurred advertising to kids, which led to the 

FTC Kids Advertising Event. 

A primary mission of the FTC is to stop deceptive or unfair acts or practices in or affecting 

commerce, which it achieves, in part, through civil law enforcement actions pursuant to Section 

5 of the FTC Act, 15 U.S.C. § 45, industry reports and workshops, and consumer and business 

education. The purpose of the Event was to provide a public forum to discuss consumer, 

industry, and academic viewpoints about kids’ cognitive abilities, the landscape and impact of 

digital advertising to kids, and any potential solutions. 

In this Staff Perspective, we highlight several issues raised at the day-long FTC Kids Advertising 

Event and in public comments filed in connection with it,4

 including the rise in blurred 

advertising, emerging research and public concerns about the ability of children to recognize and 

process it, and potential solutions. 

Key Takeaways 

What is the current digital landscape for kids? 

Kids spend a significant amount of time online. A 2021 survey by Common Sense Media found 

that 88 percent of teens between 13 and 18 have their own smartphone, and 57 percent of 

children between 8 and 12 have their own tablet.5 Further, 94 percent of families surveyed with 

kids between 8 and 18 have at least one smartphone in the home, and 74 percent have a tablet in 

the home.6 The same survey found that, on average, 8- to 12-year-olds have approximately 5.5 

hours of entertainment screen time per day, while 13- to 18-year-olds have about 8.5 hours of 

such screen time per day.7

 Entertainment screen time includes television, online videos, social 

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media, mobile gaming, and virtual environments.8 Studies show that children are consuming 

more digital content than ever before.9

 As digital media consumption increases, kids also see 

more advertising and marketing messages. By one calculation, some teenagers may see 1,260 ads 

per day.10 The more time kids spend online, the more likely they are to see ads and have their 

information collected. Moreover, as platforms find new ways to monetize influencer ads and 

other types of blurred advertising,11 the number of ads will continue to increase. 

What is blurred advertising and where do kids encounter it? 

Many of the advertisements that kids (and adults) encounter online blend into the surrounding 

content. For example, children may see marketing messages in an influencer’s video on social 

media or a video sharing platform. Some see products or services advertised as they travel 

through a virtual environment or play a mobile game. Advertisers use a wide variety of 

techniques outside traditional advertising to market products and services. These include: 

influencer social media posts12; unboxing videos13; online gaming14; paid sponsorships; virtual 

reality worlds or avatars sponsored by advertisers15; sponsored interactive social media filters16; 

and embedded ads in video sharing sites.17 

Industry and a few others claimed that this advertising may allow smaller marketers who cannot 

engage in large advertising campaigns to reach specific audiences, and that advertising more 

generally helps pay for some of the content created for kids.18 If done transparently, they argued, 

this type of advertising could be a useful tool for marketers to share products in more than a 15- 

or 30-second time frame. They also argued that restricting or curtailing this type of advertising 

could lead to: less kids’ content, a reduction in the quality of such content, or subscription 

models that require consumers to pay for access to content.19 

However, many participants expressed concern that blurred advertising allows marketers to 

disguise advertising and persuasive intent in content, and younger consumers may not be able to 

evaluate it sufficiently given their focus on the content.20 Whereas traditional ads—for example, 

ads that appear during the commercial break of a television show—are usually recognized as ads 

by children as young as 4 or 5 due to the clear delineation between the creative content and 

commercial message,21 ads that are blended into content are less distinguishable to kids.22 

Businesses now engage in blurred advertising as such a widespread practice that it has permeated 

digital media. Thus, it is impossible to know where within the content blurred advertising will 

appear, and the only way to avoid it completely is to engage in social isolation.23 Many gaming 

and social media companies have made efforts to keep kids engaged longer,24 which also may 

increase the number of ads they see. Given the number of ads kids might see in a day,25 it could 

be nearly impossible for them to actively evaluate all of these ads.26 

Not all products and services referenced in digital media are ads. For example, a celebrity talking 

to her followers in a video may mention how much she loves her new sweater. Whether such an 

endorsement is an ad depends on what is happening behind the scenes. If the celebrity received 

the sweater for free from the seller or advertiser or has a commercial relationship with either of 

them where she receives or expects to receive money, free things, or other benefits for talking 

about the sweater, her message would be considered advertising. If, instead, she is talking about 

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a sweater she purchased and she has no ties to the seller or advertiser of the sweater, it is not an 

ad.27 

The underlying relationship between the advertiser and content creators, and the audience’s 

expectation and understanding of that relationship, should dictate how these advertising 

messages are identified, keeping in mind that younger audiences may have different expectations 

than older ones, as discussed further below. 

What does emerging research tell us about kids’ abilities to recognize 

and evaluate blurred advertising?28 

Continuing questions about kids’ ability to recognize blurred advertising should concern 

marketers who nevertheless engage in the practice. Younger children tend to lack the knowledge 

and skills that would allow them to recognize and evaluate ads (“ad literacy”). These skills 

include: recognizing brands and products; researching and thinking critically about products; 

determining rules to use when making decisions; developing bargaining and negotiation 

strategies; and understanding influence, intentions, and motives.29 There is no specific age at 

which kids develop each of these skills.30 Consumer advocates and academics note that these 

issues make it difficult for kids to recognize the difference between advertising and authentic 

content. They say: 

 “When experienced by young people, stealth advertising is . . . deceptive when it is not 

clearly understood to be advertising. Its impacts are material because it directly and 

indirectly influences purchasing decisions.”31 

 “This question of being able to determine what is or is not advertising becomes really 

critical when [kids are] facing emerging technologies where they’re still trying to learn 

the ropes of how this space works and the different features.”32 

 “While the available scientific and academic literature indicates that as children age, they 

are incrementally better able to identify and then appreciate the persuasive intent of 

marketing messages, that does not mean that stealth marketing techniques do not 

deceive, exploit, manipulate and uniquely harm older children such as teenagers.”33 

By contrast, workshop participants and commenters also noted evidence that some kids may be 

able to appreciate some types of advertising, but this evidence is limited to kids’ ability to 

identify an advertisement as such, not their ability to evaluate or process the purpose of the 

advertisement. For example, research shows that children as young as preschoolers can recognize 

traditional ads in the digital space because of contextual information like the length of a 

commercial, a “skip” or “x” button, voiceovers, a call-to-action (e.g., the audience is told to buy 

something), or other features that distinguish creative content from advertising,34 and that almost 

all children can distinguish between traditional advertising and content by age 5.35 At the same 

time, research recognizes that it is much more difficult for children between 3 and 7, and 

especially between 3 and 5, to recognize embedded advertising because such contextual cues 

generally are absent.36 Further, many children under 7 have not developed theory of mind (i.e., 

the ability to think about the thoughts and feeling of others) and therefore have difficulty 

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understanding persuasive intent,37 which is necessary to fully grasp the difference between 

content and an advertisement. 

There is evidence that children in the 7- to 11-year-old bracket can understand perspectives and 

motives other than their own, as well as bias and deception in some advertising, and they have a 

more nuanced understanding of the marketplace.38 Nevertheless, the evidence once again shows 

that some children in this age group may have trouble discerning advertising from creative 

content.39 In one study, fewer than half of kids 5-11 could correctly identify an influencer ad or 

unboxing video as advertising, although recognition increased as contextual cues (e.g., skip 

button, call-to-action, disclosures, etc.) became more prominent in the examples shown.40 

Some research shows that in the 11- to 16-year-old bracket, kids have increased understanding, 

more insight into persuasive tactics, and better control over their emotions and behavior.41 

However, one small study found that even when 12- to 14-year-olds reported awareness of 

advertising on social media, they were not always able to identify commercial messages on 

social media platforms upon exposure.42 Another study showed that kids ages 12-14 were 

significantly less likely to recognize ads in sponsored influencer videos and understand their 

persuasive intent if they were shown a disclosure that failed to explain the intent of the ad (“[The 

influencer] is paid to promote [the product] during this video.”), versus one that explained the 

ad’s intent (“[The influencer] is paid to promote [the product] during this video, to make you like 

[the product].”).43 

We emphasize that the research is only developing now. Moreover, even if determined to be 

conclusive, this research does not appear to apply to neurodivergent children, who often develop 

at different ages and rates. Approximately 15 percent of U.S. kids (around 7.2 million children) 

receive special education, are typically neurodivergent, and are not accounted for in much of the 

existing research.44 Even more developed thinkers may have trouble using cues to determine who 

is offering a particular advertising message and what their motives are.45 

Children’s development also may be influenced by factors that contribute to their ad literacy, or 

lack thereof. For example, a kid’s school or family may or may not have the resources to monitor 

and teach them about advertising.46 Similarly, children’s development may depend on factors 

such as the language spoken in their home, their caregivers’ level of education, or other 

socioeconomic factors.47 

Although research in this space continues and no definitive conclusions can be reached at this 

time, on balance, the evidence clearly sends up warning flags about the problems with kids 

understanding advertising in digital media contexts. 

Is recognition of an ad enough? 

Research indicates that disclosures may in some cases help kids to identify embedded 

advertising, but they often are inadequate—either because the disclosures themselves are 

unlikely to be seen or understood by kids,48 or because they are insufficient to help kids identify 

and evaluate an embedded ad.49 

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Even if a child recognizes (because of a disclosure or otherwise) that they are seeing an ad or 

marketing message, a child’s cognitive ability must be combined with critical thinking and 

skepticism to ensure the child is thinking about bias and understanding persuasive intent.50 

Children may be less likely to use critical reflection skills because doing so could cause them to 

miss the video, game, or other digital media content in which the ad is embedded.51 Furthermore, 

if children are seeing hundreds of advertising messages embedded in the content they view in a 

given day, it is less likely that they will be motivated or have the capacity to stop and evaluate 

each one.52 Participants also posited that it might be more challenging for a kid to evaluate an 

ad’s persuasive intent or think critically about ads when advertising messages are targeted based 

on users’ interests and personal information.53 

In addition, even when children do recognize that they are viewing an advertising message and 

take the time to evaluate it, they may not grasp the full extent of the persuasive intent because of 

the subtlety of the context (e.g., social media, gaming, etc.).54 For example, in a virtual reality 

world or other immersive environment, kids may recognize an ad, but due to parasocial 

relationships,55 which may be supercharged by the use of artificial intelligence, they might be 

even less critical of attempts to persuade them.56 If kids think they are friends with an avatar or 

virtual agent, or they feel a kinship to a celebrity or influencer they follow on social media, their 

trust for these individuals and the feeling that the individuals are speaking directly to them might 

cloud their understanding of the persuasive intent.57 Research shows that when marketing is 

presented in this way, children are less likely to defend themselves against it.58 Alternatively, 

when the influencers or avatars offer more transparency around why they are recommending a 

product and what their connections are, kids understand better and have more of an ability to 

think critically.59 

What are key concerns about blurred advertising? 

While some participants pointed out benefits to ads embedded in content—e.g., increased 

availability and quality of content60—others raised concerns about the effects of blurred 

advertising61: 

 Trustworthiness/Authenticity: Influencers, avatars and others may appear to be 

authentic and genuine figures for kids, and kids may build relationships with them over 

time.62 Kids may be less skeptical of embedded ads because the ads are within content 

and delivered by people or figures they trust.63 

 Classical Conditioning/Cultural Effects: Advertising embedded in entertainment can 

create positive emotions and result in “classic conditioning.”64 An influencer sharing 

about using a beauty product is more likely to affect cultural norms and ideas about what 

is possible or “normal” than a traditional ad showing an idealized and unattainable 

physical appearance, particularly when the persuasive intent of the influencer’s message 

is unknown. The earlier these associations are established in life, the harder they may be 

to undo.65 This may increase social comparison or body image issues, especially for teens 

and tweens.66 This could be due to the parasocial relationships kids have with influencers 

or avatars, but it also may be affected by their friends being on the same platforms and 

“liking” or commenting on the content in which the ads are embedded.67 

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 Physical Harms: Physical harms may occur when blurred ads market physically harmful 

products or services, such as tanning, tobacco, or unhealthy foods, and the persuasive and 

cultural effects of embedded advertising, as discussed above, may make such products 

more desirable.68 

 Financial Harms: Blurred digital advertising may lead to accidental purchases, social or 

emotional purchases (e.g., a kid has to make a purchase to compete with another player or 

must buy food for their pet in a game), or purchases without parental approval (e.g., when 

a kid makes an in-app purchase using their parents’ account or device).69 Influencer 

marketing may spur impulsive purchases, with 25 percent of family and child purchases 

through influencers happening the same day they see the marketing message.70 

 Privacy Harms: As discussed above, the use of kids’ personal information and their 

interests to target ads to them complicates a kid’s ability to recognize and evaluate an 

ad.71 Targeted advertising is pervasive in the digital world. Even with the verifiable 

parental consent requirement of the Children’s Online Privacy Protection Act (COPPA), 

which may eliminate some targeted advertising to kids,72 children under 13 likely still 

receive targeted advertising. This can be due to non-compliance with COPPA or can 

occur when websites or online services are not specifically directed to children and lack 

actual knowledge that they are collecting data from them. 

 Disproportionate Effects on Certain Populations: Research indicates that certain 

populations may experience more significant impacts from blurred advertising, 

particularly when there is an increase in digital media usage, parents have fewer 

resources to contribute to their children’s ad literacy, English is not the parents’ native 

language, and/or the population is more likely to be targeted with potentially problematic 

ads.73 

Some participants and commenters suggested the identified concerns are overstated, speculative, 

or mitigated by various factors, such as parents acting as gatekeepers for household purchases, or 

older children developing the skills needed to help them identify and evaluate blurred advertising 

before making purchases.74 

Additional Policy Considerations 

As noted throughout this report, blurred advertising that targets children poses significant risk of 

deception and other harms. It has long been the case that children are a lucrative audience for 

advertisers. Indeed, research shows that “spending to market children’s products and services [in 

content and programming] . . . reached more than $1.6 billion in 2022,” with 70 percent spent in 

digital spaces.75 But marketers that engage in blurred advertising should be mindful that while it 

may be profitable, the practice can put children at risk of harm and violate Section 5 of the FTC 

Act. For that reason, the responsibility for ensuring lawful advertising that is free of deception 

rests first and foremost with advertisers themselves. This is especially necessary when an 

underlying commercial relationship may only be known to the advertiser and content creator.76 

Advertisers—unlike parents and children—design these commercial relationships, and carefully 

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monitor the effect of their advertising on different populations. They are therefore in the best 

position—and have the greatest responsibility—to prevent harm to children. 

In addition to marketers, platforms on which marketing takes place have a significant role to play 

in protecting children. Platforms should consider offering or promoting standardized disclosures, 

icons, or other uniform methods of transparency, and they should consider developing, 

monitoring, and enforcing policies to hold content creators accountable. However, for such 

efforts to be effective, content creators and advertisers would have to correctly identify their 

content as a paid promotion.77 No matter how advanced artificial intelligence and other digital 

tools are, it likely will be impossible to confidently identify many types of blurred advertising 

without the cooperation of the content creator and the advertiser.78 Platforms could have a role in 

education as well, given their unique ability to reach large audiences.79 

Marketers that do decide to engage in blurred advertising should not expect that parents alone 

can protect children. Placing the onus entirely on parents ignores the fact that they may not have 

the time or ability to fully monitor their kids’ screen time,80 and that it is harder to watch over a 

kid’s shoulder when they are on a small screen than when they are watching a television. In 

addition, even if parents could help increase their kids’ ad literacy by monitoring what their 

children watch and educating them on how to spot an ad and evaluate it, many acknowledge that 

even adults do not always recognize or correctly identify blurred advertising.81 

Moreover, the nature of digital content presents challenges for monitoring. Whereas traditional 

ads are more easily located and reviewed for deception or unfairness and may be shown to 

relatively large audiences that include regulators and other watchdogs, blurred ads or marketing 

messages may be tailored to, and viewed by, very small audiences. For example, a microinfluencer may have a very small following. As a result, it could make it more challenging for 

regulators (or parents) to monitor the content of such microtargeted ads.82 

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Staff Recommendations 

Today’s digital environment creates many benefits for children, but it also comes with great risk. 

Legislators and policymakers at the federal and state levels, as well as abroad, have engaged in 

thoughtful discussions and introduced legislation to protect kids from the harms presented by the 

current digital world in which they live. These global policy discussions and the research that 

continues to emerge make one thing about blurred advertising especially clear. Such advertising 

presents inherent risk, and there is no silver bullet that will address the issue of blurred 

advertising across every digital space and for every kid. Ultimately, as detailed further below, the 

best way to prevent harm stemming from blurred advertising to kids—especially in light of 

evolving research—is for marketers not to engage in the practice. 

Recognizing that such marketing may continue, however, FTC Staff has some recommendations 

that advertisers, content creators, platforms, and others can follow to reduce the likelihood of 

young consumers being deceived or otherwise harmed. The comprehensive approach 

recommends transparency, formatting, disclosures, icons, and other cues that help draw a clear 

line between content and advertising. 

Implementing any one recommendation alone is not sufficient. To address the issue of blurred 

advertising to kids, marketers and others should consider the real-world effects of their 

marketing techniques and implement all the relevant FTC Staff recommendations set forth below 

in a manner that protects children. As marketers and others consider how to implement these 

recommendations, they should keep in mind that blurred advertising targeting children comes 

with inherent risk, and companies can be held liable for any resulting deception or unfairness, 

pursuant to Section 5 of the FTC Act. 

Recommendation # 1: Do not blur advertising. There should be a 

clear separation between kids’ entertainment/educational content 

and advertising, using formatting techniques and visual and verbal 

cues to signal to kids that they are about to see an ad. 

The best way to prevent harms stemming from blurred advertising is to not blur advertising. 

Research has shown that the formatting of an ad can signal to kids as young as preschool-age 

that they are seeing an ad.83 For example, game makers, social media influencers, and other 

content creators should consider short bumpers or interstitials, such as a black or white screen, 

before and after the advertising message, similar to how ads are shown during the commercial 

breaks in television shows.84 They also could use a different backdrop when showing a product 

or service they are advertising. Verbal cues are also helpful. For example, if music is playing 

during the creative content, the music could stop for the advertising message. A voiceover—or, 

where possible, a different host85—introducing the advertised product also could help to separate 

the commercial message from the entertainment content. Similarly, statements like “we will be 

right back after these commercial messages” can signal to a kid that what follows is an ad.86 

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Advertisers and content creators should consider such formatting techniques to signal that the 

content contains a commercial message and delineate between that message and the content that 

surrounds it. 

Recommendation # 2: Prominent just-in-time disclosures should 

be provided verbally and in writing and include important 

information about the ad. 

Although disclosures alone likely are not sufficient when the advertising is embedded in content 

for younger kids, robust disclosures can play a role in helping kids identify and evaluate ads. 

Disclosures for embedded advertising in content directed at kids should: (1) be timely (i.e., 

provided at the point in time the product is introduced, and at reasonable intervals throughout the 

content, if the product is discussed or referenced for long periods of time or keeps re-appearing), 

(2) be provided verbally and in writing, and (3) include important information about the 

commercial message. 

Prominent Just-in-time Disclosures: The timing, placement, and prominence of the disclosure 

in the content matters. For example, if an entire section of a virtual reality world is essentially an 

advertisement, the advertiser and content creator should consider a watermark-type disclosure 

that re-appears at regular intervals, or that can always be seen no matter where the user goes 

inside that part of the world. Similarly, a social media influencer who has a long video that 

discusses a variety of sponsored beauty products should consider offering prominent verbal and 

written disclosures each time a sponsored product is introduced or discussed in the video, as 

appropriate,87 rather than simply providing a written or verbal disclosure at the beginning or end 

of the video.88 

Multi-Nodal Approach to Disclosures: The disclosure should be provided both verbally and in 

writing to ensure that kids will see and/or hear it.89 

Substance of Disclosures: The disclosure should be part of the description of the product itself 

and include an explanation of the sponsor’s intent. In addition, disclosures should be easy to read 

and understand.90 Kids are more likely to understand “Company ABC paid me to show you this 

so you will think about buying it” than “paid promotion” or “sponsored content.”91 

Gaming, social media, video sharing, and other platforms have an important role here too. 

Creating standard disclosures and tools for content creators to use across each platform will lead 

to more transparency and consistency. Further, platforms should consider developing and 

enforcing policies that require content providers to use such tools to identify sponsored content. 

Disclosures likely are not enough for younger children, however, and should be part of a more 

comprehensive approach based on the cognitive abilities of the intended audience.92 

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Recommendation # 3: Platforms, content creators, and advertisers 

should consider creating and using an easy-to-understand and easyto-see icon that signals to kids that money or free things were 

provided to the content creator to advertise the product. 

Icons have been explored in other countries,93 and a very prominent icon could be a useful way 

to identify ads if kids are educated to understand it.94 FTC Staff encourages the development of 

an easy-to-understand and easy-to-see icon, but an icon necessarily must be combined with 

disclosures and consumer education to ensure the intended audience knows what it means,95 and 

it ultimately should be studied to gauge its effectiveness. A proliferation of different icons is less 

likely to help kids understand what they’re seeing. 

Recommendation # 4: Education has a uniquely important role 

for kids and for the parents and educators who support them. All 

stakeholders should look for ways to educate kids, parents, and 

educators about how digital advertising works and to help kids 

recognize and evaluate it wherever it appears. 

Children are especially vulnerable to embedded advertising because many have not yet 

developed all the skills to identify and evaluate it, and because they may be especially 

susceptible to advertising messages that are introduced through parasocial relationships. One 

way to help kids recognize blurred advertising and understand and evaluate persuasive intent is 

to focus on education and ad literacy for young consumers and their parents.96 Media proficiency 

and digital citizenship, including ad literacy specifically, are widely recognized by government 

agencies and others as important to children’s development.97 All members of the digital 

ecosystem have a role to play in education. For example, a major platform has introduced an icon 

identifying sponsored content with an accompanying video that explains in simple terms what 

may have happened behind the scenes.98 The more industry standardizes the words and icons 

used to discuss embedded advertising and develops and utilizes tools for identifying it, the easier 

it may be for children to grasp the concept across media.99 Education will increase the usefulness 

of disclosures and icons as well. 

Recommendation # 5: Platforms should consider: 

(a) requiring content creators to self-identify content that includes 

advertising through policies and tools, and 

(b) offering parental controls that allow parents to limit or block 

their children from seeing such content. 

Platforms should consider offering more tools and controls to parents to help their young 

children avoid blurred advertising, recognizing that such controls depend on content providers 

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self-identifying sponsored content. As described above, to further increase the success of such 

tools and controls, FTC Staff strongly encourages platforms to develop policies regarding the 

identification of blurred advertising, and to enforce those policies when they learn of violations. 

Platforms also should consider giving parents the opportunity to turn off such content for their 

young kids, rather than requiring them to avoid certain platforms or block ads altogether. 

Although this may foreclose a significant portion of content for these children,100 it would allow 

parents more control over whether their children are exposed to blurred advertising. 

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Endnotes 

1

 FTC, Protecting Kids from Stealth Advertising in Digital Media (Oct. 19, 2022), https://www.ftc.gov/newsevents/events/2022/10/protecting-kids-stealth-advertising-digital-media (providing the agenda, speaker biographies, 

and a transcript and video recording of the event). In this Staff Perspective, references to “kids,” “minors,” or 

“children” include anyone under the age of 18. 

2

 FTC, Guides Concerning the Use of Endorsements and Testimonials in Advertising, 87 Fed. Reg. 44,288 (July 26, 

2022) (request for comment). 

3 Id. at 44,294. 

4

 Public comments submitted to the FTC Kids Advertising Event, Docket (FTC-2022-0054), are viewable at 

https://www.regulations.gov/docket/FTC-2022-0054. Any citation to “comment(s)” refers to comments in this 

docket, unless stated otherwise. 

5

 Common Sense Media, The Common Sense Census: Media Use by Tweens and Teens, at 22 (2021), 

https://www.commonsensemedia.org/sites/default/files/research/report/8-18-census-integrated-report-finalweb_0.pdf. 

6 Id. at 21. 

7 Id. at 3. 

8 Id. at 2-3. The survey also included e-books as part of entertainment screen time, but e-books accounted for only 6 

minutes for the 8- to 12-year-old group and 8 minutes for the 13- to 18-year-old group. 

9 See Melinda Wenner Moyer, Kids as Young as 8 Are Using Social Media More Than Ever, Study Finds, N.Y. 

Times (Mar. 24, 2022), https://www.nytimes.com/2022/03/24/well/family/child-social-media-use.html; see also 

Berkeley Law Consumer Protection Public Policy Order Comment (“C3PO Comment”), at 4 (“Around 40% of 

Instagram’s users are under 22 years old . . . and 22 million teenagers in the U.S. interact with the app everyday. In 

the United States, 76% of children under 18 are gamers . . . . [or] approximately 51.1 million . . . children.”) 

(footnotes omitted)); Rudd Center for Food Policy and Public Health Comment (“Rudd Center Comment”), at 1 (“In 

the United States, 27% of 5- to 8-year-olds reported following or subscribing to YouTube personalities, celebrities, 

or influencers. One-third of TikTok’s 49 million U.S. daily users are under 14 years old, and children ages 4-15 

years spend 80 minutes/day on TikTok and 85 minutes/day watching YouTube videos.” (footnotes omitted)). 

10 See Global Action Plan, Kids for Sale: Online advertising & the manipulation of children, at 10 (2020), 

https://www.globalactionplan.org.uk/files/kids_for_sale.pdf. 

11 See, e.g., Instagram, Branded Content, https://business.instagram.com/ad-solutions/branded-content (last visited 

Sept. 13, 2023); Snapchat Filters for Businesses, https://forbusiness.snapchat.com/advertising/ad-formats/filters (last 

visited Sept. 13, 2023). 

12 See Fairplay et al. Comment (“Fairplay Comment”), at 2-4, 14, xiii-xv, xviii-xxiv (describing influencer 

marketing to kids and providing examples); FTC Kids Advertising Event, Remarks of Mamie Kresses (“Kresses 

Presentation”), at 0:36; Rudd Center Comment, App. A, at 1-9. 

13 See, e.g., Fairplay Comment, at xvi-xvii; Kresses Presentation, at 0:35. 

14 See Laura Owen et al., Is Children’s Understanding of Nontraditional Advertising Comparable to Their 

Understanding of Television Advertising?, 32 J. Pub. Pol’y & Mktg. 195, 198 (2013), 

http://www.jstor.org/stable/43305783 (“Advergames, for example, are a recent Internet-based promotional tool 

designed to entice children to play in branded environments. They may be more persuasive than traditional 

television advertising as a result of the frequent use of animated imagery and children’s immersion in the game. 

Because the game itself is likely to be the focus of attention, fewer cognitive resources are available to scrutinize 

messages . . . .”); see also Kresses Presentation, at 0:24. 

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15 See, e.g., Kresses Presentation, at 0:27, 0:42; Snap, Inc., Snap Augmented Reality, https://ar.snap.com/ (last visited 

Sept. 13, 2023). 

16 See, e.g., AccessAR, How To Run Your Brand’s AR Filter Campaign (May 4, 2021), 

https://www.accessar.co/blog/how-to-run-an-instagram-ar-filter-campaign; Snap, Inc., Filters, supra n.11. 

17 See, e.g., Kresses Presentation, at 0:34. 

18 Google Comment, at 1; Interactive Advertising Bureau Comment (“IAB Comment”), at 2; The Toy Association 

Comment (“TTA Comment”), at 2; TechFreedom Comment, at 16-18. 

19 Google Comment, at 1; IAB Comment, at 2; TTA Comment, at 2; TechFreedom Comment, at 16-18; see also 

FTC Kids Advertising Event, Remarks of James Cooper (“Cooper Remarks”), at 3:22. 

20 FTC Kids Advertising Event, Remarks of Grace Ahn (“Ahn Remarks”), at 1:01, 1:59; Remarks of Liselot 

Hudders (“Hudders Remarks”), at 1:44. This concern is not new, nor is it unique to digital media. In 1974, the 

Federal Communications Commission (“FCC”) highlighted “the need for maintaining a clear separation between 

programming and advertising,” finding that “an advertiser would have an unfair advantage over listeners if they 

could not differentiate between the program and the commercial message and were, therefore, unable to take its paid 

status into consideration in assessing the message.” Children's Television Programs, Report and Policy Statement 

(“FCC Policy Statement”), 39 Fed. Reg. 39,396, 39,399, 39,401 (Nov. 6, 1974). 

21 Femke Loose et al., A Qualitative Approach to Unravel Young Children’s Advertising Literacy for YouTube 

Advertising: In-Depth Interviews with Children and their Parents, Young Consumers: Insight and Ideas for 

Responsible Marketers, at 17 (Oct. 2022), 

https://www.researchgate.net/publication/364756625_A_qualitative_approach_to_unravel_young_children%27s_ad 

vertising_literacy_for_YouTube_advertising_in-depth_interviews_with_children_and_their_parents. Traditional ads 

generally have format demarcations, different visuals, and/or interstitials. Sometimes they are combined with verbal 

or written messages, such as “we’ll be back after these advertising messages.” FTC Kids Advertising Event, 

Remarks of Nellie Gregorian (“Gregorian Remarks”), at 3:37. 

22 Gregorian Remarks, at 3:40. The FCC has said “program-length commercials, by their very nature, are extremely 

serious violations of the children’s television commercial limits, stating that the program-length commercial policy 

‘directly addresses a fundamental regulatory concern, that children who have difficulty enough distinguishing 

program content from unrelated commercial matter, not be all the more confused by a show that interweaves 

program content and commercial matter.’” Notice of Apparent Liability for Forfeiture, FCC 22-70 ¶3 (Sept. 19, 

2022). 

23 FTC Kids Advertising Event, Remarks of Josh Golin (“Golin Remarks”), at 3:02; Fairplay Comment, at 20. 

24 See FTC Kids Advertising Event, Remarks of Girard Kelly (“Kelly Remarks”), at 3:11. 

25 Global Action Plan, supra n.10, at 10. 

26 FTC Kids Advertising Event, Remarks of Jennifer Harris (“Harris Remarks”), at 3:15 (“. . . if you assume that it 

takes someone as little as 5 seconds to recognize and consciously counteract — counter-argue — one advertising 

message, which is what you would need to do to defend against it, actively evaluating 1200 messages would take up 

almost two hours of their day, and I doubt that even the most skeptical adult would be able to do that.”). 

27 The Commission has jurisdiction over commercial speech; its ability to regulate a speaker who does not have a 

commercial purpose is limited by the First Amendment. See generally Bolger v. Youngs Drug Prods. Corp., 463 

U.S. 60, 66-68 (1983); Central Hudson Gas & Elec. Corp. v. Pub. Serv. Comm’n of New York, 447 U.S. 557, 561 

(1980); see, e.g., R.J. Reynolds Tobacco Co., 111 F.T.C. 539, 539 (1988) (evaluating whether an advertisement was 

commercial speech subject to FTC jurisdiction); see also FTC Kids Advertising Event, Remarks of Genevieve 

Lakier, at 3:35 (explaining that, to qualify as commercial speech, which receives less protection than other types of 

speech, “the purpose of the speech act must be in some way to sell a product or to negotiate a commercial 

relationship”). 

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28 Existing notions of how children recognize and evaluate advertising come from historical research on kids and 

traditional advertising, as well as the limited emerging research that exists with respect to digital advertising to kids. 

Stakeholders attributed the dearth of research on kids and digital marketing to several factors: the quickly changing 

landscape of media and formatting; challenges with formulating survey questions for kids; and the difficulty of 

relying on parent responses for younger children. The Kids Advertising Event was intended to bring any relevant 

research to the forefront and encourage more. 

29 Hudders Remarks, at 1:05. 

30 Truth in Advertising, Inc. (“TINA”) Comment, at 4; see also Deborah Roedder John, Consumer Socialization of 

Children: A Retrospective Look at Twenty-Five Years of Research, 26 J. CONSUMER RSCH. 183, 187 (1999). 

31 Fairplay Comment, at 2. 

32 Ahn Remarks, at 1:01. 

33 TINA Comment, at 3. 

34 Loose et al., supra n.21, at 17; SuperAwesome Comment on Guides Concerning the use of Endorsements and 

Testimonials in Advertising (“SuperAwesome Endorsement Guides Comment”), at 3-4 (June 22, 2020), 

https://www.regulations.gov/comment/FTC-2020-0017-0087; SuperAwesome “Research data_ad recognition 2019” 

Attachment, SuperAwesome Endorsement Guides Comment (“SuperAwesome Research”), at 5-8 (June 22, 2020), 

https://www.regulations.gov/comment/FTC-2020-0017-0087. 

35 John, supra n.30, at 188. 

36 Loose, et al., supra n.21, at 17. 

37 See Matthew A. Lapierre et al., The Effect of Advertising on Children and Adolescents, 140: S2 PEDIATRICS S152, 

S153 (2017), https://doi.org/10.1542/peds.2016-1758V. 

38 Hudders Remarks, at 1:09; C3PO Comment, at 3. 

39 Hudders Remarks, at 1:09; John, supra n.30, at 185; C3PO Comment, at 3. 

40 SuperAwesome Research, supra n.34, at 23, 34-63. 

41 Hudders Remarks, at 1:09. 

42 Rudd Center Comment, at 1 (citing Margaret-Anne Lawlor et al., Young Consumers’ Brand Communications 

Literacy in a Social Networking Site Context, 50 EUR. J. MKTG. 2018 (2016), 

https://arrow.tudublin.ie/cgi/viewcontent.cgi?article=1152&context=buschmarart). 

43 Eva A. van Reijmersdal & Sophia van Dam, How Age and Disclosures of Sponsored Influencer Videos Affect 

Adolescents’ Knowledge of Persuasion and Persuasion, 49 J. YOUTH & ADOLESCENCE 1531, 1536, 1538 (2020), 

https://doi.org/10.1007/s10964-019-01191-z. 

44 FTC Kids Advertising Event, Remarks of Jenny Radesky (“Radesky Remarks”), at 1:24. 

45 See Radesky Remarks, at 1:25. 

46 Radesky Remarks, at 1:43. 

47 See, e.g., FTC Kids Advertising Event, Remarks of Sonia Livingstone (“Livingstone Remarks”), at 1:42. 

48 Fairplay Comment, at 10 (“Young children cannot read written disclosures or may be distracted by other salient or 

pleasurable features of the content. Further, children in early adolescence ‘have limited information processing skill 

and are easily distracted by visuals and moving images,’ which reduces their chance of seeing and remembering a 

disclosure.”) (citing Eva A. van Reijmersdal, Esther Rozendaal, Liselot Hudders et al., Effects of Disclosing 

Influencer Marketing in Videos: An Eye Tracking Study Among Children in Early Adolescence, 49 J. INTERACTIVE 

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MKTG. 94, 103 (2020)); FTC Kids Advertising Event, Remarks of Eva van Reijmersdal (“Van Reijmersdal 

Remarks”), at 2:06. 

49 Fairplay Comment, at 12-13 (“[R]esearch repeatedly demonstrates that even when disclosures are made, they are 

rarely noticed and are not effective at activating skepticism towards the sponsored product. Young people need 

detailed disclosures that explicitly identify the intent of the advertisement – which go far beyond the standard 

disclosure a marketer would use – in order to recognize the persuasive intent of a stealth advertisement.”). 

50 See Van Reijmersdal Remarks, at 1:12. 

51 Hudders Remarks, at 1:17; Golin Remarks, at 2:24; Harris Remarks, at 2:53. When advertising is embedded in 

content, it is harder for kids to resist ads because they are not focused on them like they are when there is a 

television break with several clearly delineated ads. When a kid assigns all their resources to watching the content, it 

is more challenging to then focus on the commercial aspect of that content. Hudders Remarks, at 1:44. 

52 Harris Remarks, at 3:15; see Hudders Remarks, at 1:32. 

53 Golin Remarks, at 2:24; Kelly Remarks, at 2:27. 

54 Livingstone Remarks, at 1:27; Fairplay Comment, at 5 n.25 (citing Agnes Nairn & Cordelia Fine, Who’s messing 

with my mind? The implications of dual-process models for the ethics of advertising to children, 27 INT’L J. 

ADVERT. 447, 448 (2015)). 

55 Parasocial relationships are one-sided relationships, in which a child (or person) feels that they know or are 

personally familiar with a media personality, almost as if they are friends. 

56 Ahn Remarks, at 1:22; Fairplay Comment, at 7-8. 

57 Radesky Remarks, at 1:50. 

58 Golin Remarks, at 2:23; Fairplay Comment, at 7-8. 

59 Radesky Remarks, at 1:50; see, e.g., Van Reijmersdal & Van Dam, supra n.43, at 1538. 

60 See supra nn.18-19. 

61 In addition to the concerns listed below, participants and commenters raised some concerns that apply more 

broadly to advertising in general. Given that the scope of the Event and subsequent Staff Perspective relate to 

blurred advertising, we address only those concerns that are unique to, or exacerbated by, this type of advertising. 

62 Rudd Center Comment, at 2 (“[A]dolescents form ‘parasocial friendships’ with influencers, believing they have a 

unique and personal relationship that makes them more likely to perceive influencers’ brand endorsements as advice 

from a trustworthy peer. Further, because social media influencers started as ‘regular people,’ they are often 

perceived as more relatable than traditional celebrities, so their endorsements may be experienced as ‘word of 

mouth’ recommendations rather than commercial ads. In addition, adolescents’ heightened sensitivity to peer 

behavior makes them vulnerable to the messages of influencers who are popular among their peers.”). 

63 Id.; Fairplay Comment, at 1; Radesky Remarks, at 2:02. 

64 Harris Remarks, at 2:56; Ibraheem Rehman et al., Classical Conditioning, NIH Nat’l Libr. Med. (Aug. 22, 2022), 

https://www.ncbi.nlm.nih.gov/books/NBK470326/#:~:text=Classical%20conditioning%20was%20stumbled%20upo 

n,placed%20in%20front%20of%20them (“Learning can occur through both unconscious and conscious pathways. 

Classical conditioning is one of those unconscious learning methods and is the most straightforward way in which 

humans can learn. Classical conditioning is the process in which an automatic, conditioned response is paired with 

specific stimuli.”). 

65 Harris Remarks, at 2:57. 

66 Golin Remarks, at 3:02. 

67 Id. at 3:03. 

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68 See Harris Remarks, at 2:55; Fairplay Comment, at 16; Rudd Center Comment, at 2 (“[A] systematic review of 

food and beverage marketing on social media and advergaming found effects on children’s food choices, 

consumption, and requests (i.e., pester behaviors). Stealth marketing of unhealthy foods in the digital space 

amplifies the effect of traditional forms of marketing, such as TV advertising, on brand recall, liking and reach.” 

(footnotes omitted)). Jennifer Harris also discussed an experiment in which kids offered snack foods after playing 

online games with embedded ads for different unhealthy snacks consumed 50 percent more calories from unhealthy 

foods than the kids whose games did not have those ads. Harris Remarks, at 3:04 (referring to Jennifer L. Harris et 

al., US Food Company Branded Advergames on the Internet: Children's Exposure and Effects on Snack 

Consumption, 6 J. CHILD. & MEDIA 51 (2012)); see also TINA Comment, at 8. 

69 See, e.g., Complaint at 3-13, In the Matter of Epic Games, Inc., Docket No. C-4790 (2023), 

https://www.ftc.gov/system/files/ftc_gov/pdf/1923203EpicGamesComplaint.pdf (alleging that Epic Games tricked 

consumers, including kids, into making unintended purchases); Kresses Presentation, at 0:30 (discussing four CARU 

cases regarding manipulative in-app purchase schemes aimed at kids). 

70 Golin Remarks, at 3:09 (“[T]here was a study by Super Awesome that showed that . . . 25% of purchases in the 

family and children category through influencer purchasing happened that same day and another third happened in 

the next few days. So this is designed to . . . lead to those impulsive purchases. It’s never been easier to make an 

impulsive purchase when all you have to do is click on something. And to expect parents to monitor what’s going on 

six to eight hours a day while their kid’s online, I think, is completely unrealistic.”); Tiffany Tasker, Use KidDirected Content to Create More Effective Campaigns, THE TOY BOOK (Feb. 20, 2022), 

https://toybook.com/marketing-memo-kid-directed-content/). 

71 See supra n.53. Some kids may even provide more information to marketers because they do not realize they are 

interacting with an ad. 

72 FTC Kids Advertising Event, Remarks of Sheila Millar (“Millar Remarks”), at 2:28. Targeted advertising to kids 

requires verifiable parental consent and therefore may reduce the amount of targeted advertising kids receive. 

73 See, e.g., Harris Remarks, at 3:09. (“There are a number of reasons the harms are greater for families of lower 

socioeconomic status and especially in communities of color. Low-income families don’t have as much access to 

high quality daycare, after school programs, or safe parks and streets, so children in those families tend to spend 

more time with media.”); Rudd Center Comment, at 2 (“In addition, companies have long created racially targeted 

ads, which are powerful marketing tools that use cultural symbols, actors of a specific race/ethnicity, or language to 

convey inclusivity and appeal to the targeted group. Food marketing likely contributes to racial disparities in dietrelated diseases. Black youth view, on average, 70% more unhealthy TV food ads than white youth view.” 

(footnotes omitted)). 

74 See, e.g., Cooper Remarks, at 2:45, 3:13; Remarks of Lartease Tiffith (“Tiffith Remarks”), at 4:19; Millar 

Remarks, at 2:59; IAB Comment, at 3-4; TTA Comment, at 2, 5. 

75 Karlene Lukovitz, Ad Spend in Kids’ Content/Media Leapt Nearly 50% in 2022, Driven By Digital Video, Digital 

News Daily (Jan. 19, 2023), https://www.mediapost.com/publications/article/381723/ad-spend-in-kidscontentmedia-leapt-nearly-50-i.html (“Even as many other verticals have seen a reduction in ad spend, U.S. ad 

investments in children’s content and programming grew by nearly 50% in 2022, driven primarily by digital video, 

according to a study by MediaRadar.”). In addition, certain types of advertising susceptible to blurring remain 

popular with marketers. For example, an estimated “75 percent of marketers now include[e] social-media 

influencers in their marketing plans.” Center for Digital Democracy Comment, at 7 (quoting Farrell et al., What 

Drives Consumers to Engage with Influencers?, 62 J. ADVERT. RSCH. 1 (Mar. 1, 2022)). 

76 FTC Kids Advertising Event, Remarks of Josh Blumenfeld (“Blumenfeld Remarks”), at 4:02; Tiffith Remarks, at 

3:43. 

77 Blumenfeld Remarks, at 4:02. 

78 Blumenfeld Remarks, at 4:09; see FTC Kids Advertising Event, Remarks of Sneha Revanur (“Revanur 

Remarks”), at 4:13. 

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79 See, e.g., Fairplay Comment, at 4 (“Large online platforms continue to be the most popular places to engage in 

stealth advertising via influencers”). Some platforms have engaged in efforts to educate young people about digital 

media. See, e.g., Google, Internet Keep Safe Coalition, and The Net Safety Collaborative, Digital Safety and 

Citizenship Curriculum (June 2021), https://storage.googleapis.com/gweb-interland.appspot.com/enus/hub/pdfs/2021/BIA_Curriculum_June-2021_EN_PDF-Version.pdf. 

80 Radesky Remarks, at 1:43; Gregorian Remarks, at 4:18 (explaining that relying on parents as gatekeepers is a 

challenge for all households and may be impossible for lower income families, recent immigrants, or households 

with fewer resources). 

81 Kresses Presentation, at 0:46. 

82 Golin Remarks, at 3:17. 

83 See John, supra n.30, at 188. 

84 Gregorian Remarks, at 3:38; see also FCC Policy Statement, 39 Fed. Reg. at 39,401 (discussing special measures 

such as showing “some form of visual segment before and after each commercial interruption which would contrast 

sufficiently with both the programming and advertising segments of the program so as to aid the young child in 

understanding that the commercials are different from the program”). 

85 The FCC has long condemned host-selling during children’s television programming. FCC Policy Statement, 39 

Fed. Reg. at 39,401. 

86 Id. 

87 See Gregorian Remarks, at 3:50; Revanur Remarks, at 3:49. 

88 See FTC, .Com Disclosures: How to Make Effective Disclosures in Digital Advertising, at 19-20 (2013), 

https://www.ftc.gov/system/files/documents/plain-language/bus41-dot-com-disclosures-information-about-onlineadvertising.pdf. 

89 Gregorian Remarks, at 3:50; Blumenfeld Remarks, at 3:47 (explaining Google’s research showed that a multinodal solution worked best, especially because it accounts for kids with different developmental milestones. The 

three elements that helped kids grasp the concept of embedded advertising were: a distinctive visual icon, easy-toread text, and a fully animated educational video); see also, FTC Kids Advertising Event, Remarks of Bonnie Patten 

(“Patten Remarks”), at 3:53. 

90 Revanur Remarks, at 3:49. 

91 Van Reijmersdal Remarks, at 2:06; Van Reijmersdal & van Dam, supra n.43, at 1538; Blumenfeld Remarks, at 

3:47 (explaining that Google’s research showed only one out of ten kids understood the phrase “includes paid 

promotion,” that young kids could not read it, and that older kids struggled to understand what it meant); see also 

Gregorian Remarks, at 4:27. When Google used the disclaimer “This channel got money or free things to make this 

video” in an animated educational video linked through an icon, it reported that 9 out of 10 kids read the text and 

could identify three things: the “creator received money or free things,” that a “company provided the creator with 

the thing,” and that “the company gave the free thing to the creator because they’d like to get kids or you to buy 

something.” Blumenfeld Remarks, at 3:48. 

92 Revanur Remarks, at 4:04 (explaining that the use of disclosures should be combined with other solutions); FTC 

Kids Advertising Event, Remarks of Bonnie Patten (“Patten Remarks”), at 3:44. 

93 Van Reijmersdal Remarks, at 2:04. 

94 Gregorian Remarks, at 3:54 (explaining that kids can pick up on the meaning of icons rather quickly). 

95 Patten Remarks, at 3:53. 

96 Millar Remarks, at 3:20; Patten Remarks, at 4:23 (“[L]earning about these deceptive tactics of stealth marketing, I 

think, will go a long way to empowering children . . . to protect themselves better.”); Gregorian Remarks, at 4:24 

(“[A] really concerted effort in introducing into media literacy curriculum topics about advertising, about stealth 

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advertising, and especially new forms of advertising in immersive environments, could be potentially very, very 

powerful.”); Tiffith Remarks, at 4:29 (discussing the need to educate parents, as well). 

97 Media Literacy Now, Media Literacy Policy Report (2022), at 4-12, https://medialiteracynow.org/wpcontent/uploads/2023/05/MediaLiteracyPolicyReport2022.pdf (finding that “18 states have media literacy education 

language on the books” and detailing state requirements and guidance for media literacy in schools); Politico, New 

Jersey becomes first state to mandate K-12 students learn information literacy (Jan. 4, 2023), 

https://www.nj.gov/governor/news/news/562022/20230104b.shtml; see also, supra n.81. 

98 See, e.g., Blumenfeld Remarks, at 3:48, 4:25 (discussing YouTube’s icon, disclosure, and educational video about 

paid product placement and related research results); Google, For Kids & Families: What Are Paid Product 

Placements, Sponsorships & Endorsements?, https://support.google.com/youtube/answer/10502576?hl=en (“When 

you see this button on a video, it means the person who made the video might get money or free things from a 

company to make it.”). 

99 Gregorian Remarks, at 4:27. 

100 See, e.g., Patten Remarks, at 4:16; see also Tiffith Remarks, at 4:14 (discussing issues relating to ad blocking); 

Cooper Remarks, at 3:22. 

20