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Under COPPA, how do I know if my channel is “directed to children”? Since the FTC and New York Attorney General announced their September 2019 settlement with YouTube for violations of the Children’s Online Privacy Protection Act Rule, we’ve heard that question from channel owners – sometimes called content creators. If you’re a channel owner who shares content on user-generated platforms like YouTube, read on for FTC staff guidance about the applicability of the COPPA Rule and how those covered by the Rule can comply with its requirements.

The FTC action against YouTube and Google

The lawsuit against YouTube and Google alleged that the companies illegally collected personal information from children, in violation of COPPA. According to the complaint, the companies collected that information from viewers of child-directed YouTube channels in the form of persistent identifiers that track users across the Internet, but didn’t notify parents and get their consent. To settle the case, YouTube and Google agreed to create a mechanism so that channel owners can designate when the videos they upload to YouTube are – to use the words of COPPA – “directed to children.” The purpose of this requirement is to make sure that both YouTube and channel owners are complying with the law.

A COPPA recap

That provision of the settlement has raised questions among content creators about how to determine if what they upload to YouTube or other platforms is “directed to children.” The answer requires a brief summary of some key COPPA provisions. Passed by Congress in 1998, the Children’s Online Privacy Protection Act is a federal law that protects the privacy of children under 13. COPPA’s foundational principle is one that most people can agree on: Parents – not kids, companies, platforms, or content creators – should be in control when it comes to information collected from children online.

The FTC enforces the law through the COPPA Rule. In general, COPPA requires operators of commercial websites and online services that are directed to children (more about that in a minute) to provide notice and obtain verifiable parental consent before they collect personal information from kids under 13.

The COPPA Rule defines “personal information” to include obvious things like a child’s first and last name or home address, but that’s not all. Under COPPA, personal information also covers what are called persistent identifiers – behind-the-scenes code that recognizes a user over time and across different sites or online services. That could be an IP address or a cookie when it’s used to serve targeted ads. Keep in mind that an operator also might be collecting personal information through an open comment field on its site or service that allows a user under 13 to make personal information publicly available. For example, think of a comment like this on a child-directed site: My name is Mary Jones from Springfield. I love this video!

How COPPA applies to channel owners

So how does COPPA apply to channel owners who upload their content to YouTube or another third-party platform? COPPA applies in the same way it would if the channel owner had its own website or app. If a channel owner uploads content to a platform like YouTube, the channel might meet the definition of a “website or online service” covered by COPPA, depending on the nature of the content and the information collected. If the content is directed to children and if the channel owner, or someone on its behalf (for example, an ad network), collects personal information from viewers of that content (for example, through a persistent identifier that tracks a user to serve interest-based ads), the channel is covered by COPPA. Once COPPA applies, the operator must provide notice, obtain verifiable parental consent, and meet COPPA’s other requirements. For information on how to comply with COPPA, please visit the FTC’s COPPA page for our Six-Step Compliance Plan for Your Business.

How channel owners can determine if their content is directed to children

Under COPPA, there is no one-size-fits-all answer about what makes a site directed to children, but we can offer some guidance. To be clear, your content isn’t considered “directed to children” just because some children may see it. However, if your intended audience is kids under 13, you’re covered by COPPA and have to honor the Rule’s requirements.

The Rule sets out additional factors the FTC will consider in determining whether your content is child-directed:

  • the subject matter,
  • visual content,
  • the use of animated characters or child-oriented activities and incentives,
  • the kind of music or other audio content,
  • the age of models,
  • the presence of child celebrities or celebrities who appeal to children,
  • language or other characteristics of the site,
  • whether advertising that promotes or appears on the site is directed to children, and
  • competent and reliable empirical evidence about the age of the audience.

The determination of whether content is child-directed will be clearer in some contexts than in others, but we can share some general rules of thumb. First, unless you’re affirmatively targeting kids, there are many subject matter categories where you don’t have to worry about COPPA. For example, if your videos are about traditionally adult activities like employment, finances, politics, home ownership, home improvement, or travel, you’re probably not covered unless your content is geared toward kids. The same would be true for videos aimed at high school or college students. On the other hand, if your content includes traditional children’s pastimes or activities, it may be child-directed. For example, the FTC recently determined that an online dress-up game was child-directed.

Second, just because your video has bright colors or animated characters doesn’t mean you’re automatically covered by COPPA. While many animated shows are directed to kids, the FTC recognizes there can be animated programming that appeals to everyone.

Third, the complaint in the YouTube case offers some examples of channels the FTC considered to be directed to children. For example, many content creators explicitly stated in the “About” section of their YouTube channel that their intended audience was children under 13. Other channels made similar statements in communications with YouTube. In addition, many of the channels featured popular animated children’s programs or showed kids playing with toys or participating in other child-oriented activities. Some of the channel owners also enabled settings that made their content appear when users searched for the names of popular toys or animated characters. Want to see the FTC’s analysis in context? Read pages 10-14 of the YouTube complaint.

Finally, if you’ve applied the factors listed in the COPPA Rule and still wonder if your content is “directed to children,” it might help to consider how others view your content and content similar to yours. Has your channel been reviewed on sites that evaluate content for kids? Is your channel – or channels like yours – mentioned in blogs for parents of young children or in media articles about child-directed content? Have you surveyed your users or is there other empirical evidence about the age of your audience?

What are the possible penalties for violating COPPA?

The Rule allows for civil penalties of up to $42,530 per violation, but the FTC considers a number of factors in determining the appropriate amount, including a company’s financial condition and the impact a penalty could have on its ability to stay in business. While Google and YouTube paid $170 million, in another COPPA case settled this year, the operator paid a total civil penalty of $35,000.

Isn’t the FTC taking another look at the COPPA Rule?

Yes, the FTC is currently evaluating the Rule in light of rapid changes in technology. If you would like to comment on the effectiveness of the COPPA Rule and whether changes are needed, the FTC has extended the comment deadline to December 9, 2019.

Where can channel owners go for more information?

A look at the factors in the COPPA Rule will help most channel owners determine if their content is directed to children. If you’re still unsure about how COPPA applies to you, consider contacting an attorney or consulting with one of the COPPA Safe Harbor programs – self-regulatory groups that offer guidance on how operators can comply with the law. Visit the FTC’s website for a list of currently approved Safe Harbor organizations. For more resources, visit the FTC’s Children’s Privacy page for our Six-Step Compliance Plan for Your Business.



Roy (not verified)
April 23, 2020

In reply to by Riley (not verified)

I was scrolling just to see if anyone else was thinking that too
Sabrina (not verified)
January 07, 2020

In reply to by Guest (not verified)

I absolutely agree. As a mom of 4 I monitor what my kids watch and what sites they go to. It is the parents responsibility to make sure their children aren't going on sites or channels they shouldnt be. Not to mention as you said many adults and teens still love dolls, collectables, games crafting, art etc.that can be seen as for kids. In my option I think this is just another way for those in power to try and pull the control of people finding alternative ways to generate income that leaves them out. Its ridiculous.
Anonymous (not verified)
January 10, 2020

In reply to by Sabrina (not verified)

I don’t think it’s a good idea. Being a YouTuber is a real job to some people and some minor Channels might come out of business because of it. If you monitor your child’s actions, you should only let them watch YouTube Kids, which is a separate app for kids under thirteen and has similar rules to what COPPA and the FTC are bringing in. I don’t think anybody who has a good understanding of YouTube’s algorithm and policy’s should agree.
Lil toad (not verified)
January 21, 2020

In reply to by Anonymous (not verified)

I absolutely agree with whom ever you are. Youtube to me is a REAL job and I am absolutely scared that my channel could become nothing. My videos are "kid friendly" but they are not indented for children at all. Also I am just a starting channel and i cant afford loosing it now. Technically this isn't a job yet it is just volunteering. People do see this as a job to feed families and do what people with a "normal job" would do. There for it is not fair that people's jobs are at risk because parents allow their children to go onto regular youtube instead of kids.
Yurgi Yurge (not verified)
March 15, 2020

In reply to by Guest (not verified)

Yeah, you have a point. I'm an adult who still watches old cartoons and play video games. They should elaborate on that. They exaggerated a bit on this is made for kids and that is made for kids. Adults can like stuff for kids and vice versa. Anime games are rated T for teens and even children play those games. How can it be kids content if the rating says something else. I want to upload Minecraft videos, but they may consider it as for kids, kids are not the only ones who play Minecraft, there are adults and teens who play it too. I aim to entertain a general audience. What if I use words that can be used for anything and they consider it as for kids? Cool means that's awesome. But what if I use some words from a different language? Not everyone can pay that fine.
Sebastian (not verified)
March 21, 2020

In reply to by Guest (not verified)

I was trying to make a childhood show playlist and I couldn’t put it in a playlist and it wouldn’t let me
Larry (not verified)
April 05, 2020

In reply to by Guest (not verified)

If device is not being used for kids, need we should have the options to turn it off. So we can save items like new rvs, food articles etc.
Natalie Luna (not verified)
April 06, 2020

In reply to by Guest (not verified)

i want coppa to be gone put back the playlist live chat notification Bill everything and I don't want kisses channels to be affected by this and by you I want it back NOW
Guest (not verified)
June 14, 2020

In reply to by Guest (not verified)

I agree. Children lie about their age on a lot of things on the internet. That applies for youtube. Also some of the things YouTube disables (Miniplayer and etc.) don't have anything to do with children or COPPA.
Derrick Henderson (not verified)
July 07, 2020

In reply to by Guest (not verified)

I'm not a child. I'm 42 years old. Y'all doing this to hide truths.
Brandon Dixon (not verified)
November 22, 2019
This honestly doesn't clarify much if anything at all. This really is saying if you're playing something like Skylanders, Zelda, Sonic, LEGO, Spyro, etc. Then it's for kids cause nothing supposedly adult (At least according to this criteria) is happening in those games. Even when your content is directed towards older audiences and you're doing something like a Speedrun, a game review, an online match and the like, What I reading is if I was playing an online match of something like Pokemon, a game that people of all ages play. Because it's Pokemon a game that is tailored to kids then it's just for kids. Regardless of what my audience is.
Guest (not verified)
November 27, 2019
What about channels that provide independent commentary and use animation or clips of things considered for kids? Are they problematic under COPPA?
MAHARNAV (not verified)
December 20, 2019

In reply to by Guest (not verified)

Sir I am having a old account of YouTube in my fully not working phone . And I created and posted videos in 2018 , and now I can't access that channel . And also now I can't do any coppa setting their . So what will I do?
Adam (not verified)
December 21, 2019

In reply to by MAHARNAV (not verified)

that is the sort of thing i was worried about too. what if i upload content that is not directed to kids, but towards teens and even adults? i can set the setting so that my channel is not directed at kids, and coppa will see it, but the thing is, "will i be fined?" i dont mind not getting any revenue from the videos i produced, as long as im not whacked by that heavy fine, im okay
Guest (not verified)
November 22, 2019
Almost every video on YouTube contradicts with one to all of the guidelines listed on this page., we need simple rules that all of us can follow.
Moon (not verified)
November 28, 2019

In reply to by Guest (not verified)

Simple rules to follow would be great for a YouTuber like me so I can keep uploading content for all my subs. It's fun to be a YouTuber but all these non-simple rules may lead to me deleting my channel. I very much agree that the rules need to be simple.
FTC Staff
November 29, 2019

In reply to by Guest (not verified)

The complaint in the YouTube case offers some examples of channels the FTC considered to be directed to children. For example, many content creators explicitly stated in the “About” section of their YouTube channel that their intended audience was children under 13. Other channels made similar statements in communications with YouTube. In addition, many of the channels featured popular animated children’s programs or showed kids playing with toys or participating in other child-oriented activities. Some of the channel owners also enabled settings that made their content appear when users searched for the names of popular toys or animated characters. Read pages 10-14 of the YouTube complaint to see the FTC’s analysis in context.

Concerned creator (not verified)
November 30, 2019

In reply to by FTC Staff

What about channels that have mixed stuff? I make unboxing videos of toys, i have game videos(ranging from mature games to family friendly games), , travelling vblogs and pets. My channel is not monetized, i make no money from my videos, i have never applied for monetisation. I have never stated anywhere that i aim my content for children, and i do not, my audience is general audience, and youtubes stats show that most people who watch my videos are between the age of 18-34 I speak foreign languege in my videos as i am not the citizen of usa or any other english speaking country, but i add subtitles in english into my videos. Am i safe? Do i need to make my channel made for children as i do not aim my videos for kids? It is not made for children it is made for all people, and mostly toy collectors watch my unbox videos. I am very scared that youtube has a bot that can just go and cnahne your video for you if it deems it made for kids, and then you can sue me for thousands of dollars even though i do not even live in usa. I do not have that kind of money, on some months i can just barely buy food for myself and pay my rent. That would kill me.
royal ridoy (not verified)
April 07, 2020

In reply to by Sunil Mandavi (not verified)

Thanks dear
Mark (not verified)
December 27, 2019

In reply to by FTC Staff

I dont get money for my videos its just for fun will i get fine? Should I just delete everything?
Ralph Hancock (not verified)
November 29, 2019

In reply to by Guest (not verified)

Would be nice, but it's not a simple world. I think adjudication of cases has to be based on principles, rather than arbitrary precedents. To your point, one of those principles has to be "due process": You can't fine people for breaking a rule that is misleading, vague or contradictory.
Mfundi Soyingwa (not verified)
November 22, 2019
I know at this point you won't listen to me but not all animated shows are directed to children : *Most fictional stories in the modern era were cater made for teenagers and adults Examples include Harry Potter franchise The Hunger Games Divergent Lord of The Rings To name a few (it would take me 5-10 years to list them all) *Approximately +-90% of animated and fictional content from the eastern side of hemispheres, usually in Asian countries such as Japan, Korea an China, are catered towards teenagers and adults Examples include: Bleach Black Clover Berserk Boku no Pic To name a few(If I continue on it take me at least 20+years) *Even though they're both animated Anime (Eastern Animation) & Cartoons(Western Animation) are two different mediums that are handled from a cultural perspective Examples include: Language difference Art styles difference Difference in storytelling Differences in target audience *Most of the Older & Modern Western Animations are directed towards teenagers and Examples include Rick and Morty South Park The Simpsons (before Fox was bought out) Family Guy (//) The Cleveland Show To name a few (again it will literally take me +-20 years to list them all) *Most Video Games were not designed for kids enjoyment Examples include: Outlast Doom Halo Street fighter Guilty Gear To name a few (//) Most of the Content creators on YouTube should not be punished (at least the ones who actually make videos related to Pop culture references) and in actuality the parents who are complaining on these matters should be punished for allowing their child/children to have unrestricted internet in the first place (no matter what YouTube the dark web still exists and no matter how much you try to make the internet child friendly their information will never be truly safe) it is thanks to their negligence of filter systems and their non-parenting principals of blindly trusting their kids with online access that these issues arise
Jose Vega (not verified)
November 22, 2019
Why aren't you guys considering to add mixed content. Mixed content would solve this problem and it would make things easier. Why must you make our fight to have you listen even harder? Mixed content is an alternative that I feel would please everyone. Because even though there can be content that appeals to kids, they can appeal to adults as well. You all just don't understand and I personally feel that you are out of touch. I will continue my fight as is everyone else in the hopes that we can convince you to listen. Sure you are listening but it's not enough. It's never enough. We want you to know that we want you guys to leave content creators alone. We aren't the reason why YouTube got in this predicament, YouTube and it's CEO did on their own with their machine-learning systems. We end up paying the price for what they did and now you decide to punish us. That's inexcusable. Please consider adding a mixed content option because that would not only solve this whole mess but it can favor everyone and we won't have to be worrying and dreading and what not. I only pray that you will consider.
Guest (not verified)
November 28, 2019

In reply to by Jose Vega (not verified)

It's YouTube who chose not to put in a "generalized audience" option. Go blame them.
Guest (not verified)
December 30, 2019

In reply to by Guest (not verified)

That wouldn't solve anything. It's been stated that if it's mix audience, you still have to put in the kids catagory. Because it's still technically kids friendly. But older audiences will get your video suggestion. YouTube isn't to blame, their following the law. As they should. Though the changes are questionable. It's not their choice.
Guest (not verified)
November 28, 2019

In reply to by Jose Vega (not verified)

FTC has a mixed content option. The problem is that Youtube isn't including that with us. If you're upset about lacking a mixed content option, th proper people to complain to would be Youtube.
Eric Curry (not verified)
November 28, 2019

In reply to by Jose Vega (not verified)

Mixed content is acknowledged by the FTC, under the term 'general audience.' It is an option, but if children access it you cannot be aware of it.
Kati (not verified)
November 29, 2019

In reply to by Jose Vega (not verified)

I think this was addressed above. "Second, just because your video has bright colors or animated characters doesn’t mean you’re automatically covered by COPPA. While many animated shows are directed to kids, the FTC recognizes there can be animated programming that appeals to everyone." The bottom line there is who your target audience is. If you are family-friendly and target adults, it seems to me that you wouldn't likely fall under COPPA at all. Most adults won't watch someone play with toys for hours on end (ie child-directed content), but many kids are interested in adult-directed content.
GiveMeYourTP (not verified)
July 24, 2020

In reply to by Kati (not verified)

Actually most adults collect figures . I am 29 and I collect them. Also I am technically special needs as Well but I know a lot of adults who collect figures special needs adults and non special needs a like. The whole this is for kids and this is not for kids is never simple some figures are intended for 15 and up and 17 and up.
Somps (not verified)
December 01, 2019

In reply to by Jose Vega (not verified)

Because then YouTube would have to view the videos and they don't want to have to do that. That's a great idea, but then YouTube could possibly get held for it and by doing it this way, there isn't any way they can be found at fault. They don't care about users.
ThisIsAPlatfor… (not verified)
December 06, 2019

In reply to by Jose Vega (not verified)

Mixed content wont help. This would still mean if any part of your audience is kids then the proper actions to prevent data collection must be taken. Mixed content is basically the same thing as kids content. The only thing that would solve this problem is for youtube to have two very hard lined sites with one being all content uploaded to "Youtube" being data collecting inventory, and then a "Youtube Kids" that clearly does not collect data. Kids content may be allowed on regular "Youtube" but any adult sharing the platform with a child would be consenting to the data being collected. Youtube needs to do a better job of controlling their content distribution. But Youtube clearly wants the childrens data, and is apparently going far out of the way to try to keep the kids content together with all adult content that collects data because they damn well know how much money they make from targeted ads on those videos. There should be two platforms and the registration process for an adult account should have some form of verification system.
Jessica Zukas (not verified)
December 07, 2019

In reply to by Jose Vega (not verified)

I believe that it was YouTube that only gave the options "for kids" and "not for kids"- if you are upset there's not at general audience option upon uploading a video at least. They made it too simplistic but in That case your fight is with YouTube. And yes it needs to change. YouTube is mad that they got 170 Mill taken. They are airing creators out to dry because of it and not being helpful at all.
Nate (not verified)
December 17, 2019

In reply to by Jose Vega (not verified)

They just announced that I you make mixed content, your free to put it on Not for Kids.
JC (not verified)
November 22, 2019
Vague definitions and a wonky Google/YouTube algorithm in response to the YouTube/FTC settlement can lead to false positives that impact content creators negatively in most cases slapping them with heavy fines that far outweigh the money they make from posting their content on sites like YouTube. One offense is a $42,000 USD fine. given how little content creators make with subscriptions and ad revenue, this could lead to the essential shutdown of their channel.

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