YouTube channel owners: Is your content directed to children?

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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.



FTC if your actually reading this comment stop youtube is a platform that thrives the people who run it get payed the people who make the content get payed and the people who watch the content either get a kick out of it learn something or are a fan of the content creator its a universal platform that helps and entertains so stop this act can put familys into poverty shut down bisnises and attract a lot of hate towards you so stop

There is many channels that repaint dolls that might be deemed as for kids even though they're an art channel that uses many chemicals and tools that aren't for kids...there are many channels that are in this gray area of content that might be intended for everyone, but marked as for kids...this will substantially decrease their income...

What are they supposed to do now? Use explicit language in every video to not be marked as for kids

Please take time to thoroughly make rules and creators aren't just playing a legal guessing game
Real people's lives are at stake here

Adding violence, blood, explicit language or other elements to content will not necessarily mean that the content is not child-directed. As described in the blog, the FTC will consider the factors set forth in the Rule to determine whether content is directed to children.

I do family friendly animation. So do I put for kids?

I hate this so much!!! Some of my favorite YouTubers have to cancel their entire channel thanks to coppa. Yeah it has cartoons, vibrate colors, jokes, and other silly stuff but older kids and adults can like that too. So you can’t say that only Kids can watch it. Anyone can, why because they want to. Coppa and TFC is being totally unfair. Bye

Now for example couldn't you enforce the users to just put 14+ for this animations because if you were to enforce this we could still enjoy this animated content but because of the 14+ it would tell the kids and parents that this animation is directed to the older demographic because I want to enjoy these and not have them taken off.

if the animated character done tons of violence, are you sure those are for child?

I just started a YouTube channel. While my content is not SPECIFICALLY for children, the RISK of a $42,000 fine is NOT worth keeping our vacation videos on YouTube, even if the FTC says there is no danger. My plan is to remove EVERY SINGLE VIDEO I have posted and wait until this is resolved. If it is not, I will NEVER post a single video with the possibility that a bot, an algorithm, or a FTC employee will consider it children's content, EVEN IF I mark it "MADE FOR ADULTS." This is frankly confusing. Wish there was another way to resolve this problem without stressing out YouTube Channel owners.

Does a Mario playthrough count as kid friendly content

This is dangerous for kids, once all kids content is eliminated on youtube they will start to watch what left.. adult content. then what next? blame the creators..

One would assume this law affects content creators in the United States. What about children's videos from other countries? Who is to say a child in the US cannot simply click a children's video from England, Australia or Japan?

Foreign-based websites and online services must comply with COPPA if they are directed to children in the United States, or if they knowingly collect personal information from children in the U.S.

The law’s definition of “operator” includes foreign-based websites and online services that are involved in commerce in the United States or its territories. As a related matter, U.S.-based sites and services that collect information from foreign children also are subject to COPPA. See COPPA FAQS B.7.

Sir the Tencent game pubg has been watch by small kids and upper age audience also What option did we can choose ? Pls help

"the subject matter" - I have videos about and against school bullying. Children watching it, but parents and teachers too. Even if it's not for little kids. What now?

"visual content" - Like what?

"the use of animated characters or child-oriented activities and incentives" - Animated characters from shows like Family Guy and South Park? Those are animated shows but adult shows.

"the kind of music or other audio content" - What does this even mean? Are all happy music is for children?

"the age of models" - Kids are in horror movies. Are horror movies considered "content for kids"?

"the presence of child celebrities or celebrities who appeal to children" - Celebrities like Santa Claus?

"language or other characteristics of the site" - What language? Kids speak the same language as adults. Adults are using the same slags as kids, as everyone is using the same hip language on the Internet.

Nothing is exact about this. Every Youtube video creator need like 12 lawyers just to figure out the basics, but not even lawyers can do that because these rules/laws are all gray areas. So anyone can get sued anytime for any content. Sounds fantastic...

this is dumb. a very large majority of people that watch youtube. are above these ages there is no reason to take the money people need. these are peoples jobs. how would main stream media like it if we made kids shows illegal. thats what you are doing. these kids have a choice to watch these videos. there's no reason to blame the creators.

A lot of youtubers are doing their absolutely best to keep their channels running strongly while indicating that their content are each for distinctive audiences. Some are for children, some are for adults and some are for both. To heavily fine an individual for doing their job without specific guidelines outside of the basic ones listed is not only scary, but also potentially illegal. Please don’t let content creators fall victim to ruining their lives altogether.

It should not be the responsibility of a YouTube creator to parent/police someone else's child. If a parent choose to blindly allow their children to watch YouTube and it's content then that's on the parent not the creator of the content. If anything since it is a video, just as films, tv and games allow YouTube to also have a rating system for the content for which it is created. Creators and fellow watchers of creators should not be punished because parents are lazy. Oh, by the way I am a mother of two now young men, who policed my children while watching tv, playing games, watching videos, listening to music and such because that is and was my responsibility as their mother not someone else's.

As an avid You Tube viewer of art content (tutorials, classes and general information related to art I think that the enforcement of these rules, with the vauge definitions will cripple much of the content that I so enjoy. Surely a rating system (i.e. P, PG, R) would ease the burden of providers in deciding what content is "child directed"

This is so stupid. So many youtubers will be fined for no reason

Is this a problem with content being directed to children or illegally collecting information from them If its just the latter anyone on youtube could just repost all their content on pornhub in theory Nonsensical If its the former literally everything from Nintendo and Disney to GTA and mortal combat is illegal by your standards Clearly problematic

How do you reconcile the rules against collecting children's information with the fact that channel owners DO NOT collect any information? YouTube collects that. Channel owners have no access to that info and couldn't stop that info from being collected if they wanted to. By punishing the channel owners for collecting the information (something they're not doing), you're not even going after the people with the power to stop the violation from happening. How is that either protecting children or enforcing the law? Also, how can you possibly call $40k+ against a single citizen or small business a reasonable fine? Our Constitution protects against excessive fines in the eighth amendment. How is this sort of thing not unconstitutional? I would say that it definitely is, and if you insist on pushing it through, I think it's only a matter of time before the judicial system rules against you on that matter. (I'm not a YouTuber and have deleted the handful of decade-old videos I had listed because of COPPA, rather than risk a life-destroying penalty because of something I'm not doing. But this is of great concern to me as a creator of other types of media/content because it's also a direct attack on our freedom of speech--another thing the Constitution protects and which our government should be working to uphold rather than destroy.)

Please understand that it's not the creators' fault that they make child friendly content or content directed to children many of these content creators create content to make money to sustain wealth for their family and when they were getting demonitized that meant they would no longer make money from their cont they were getting demonitized because they were making adult content so they fixed that by becoming family friendly which means that children under 13 could watch their content with permission from their parents. Also, your categorization of kid content is not fair because, such as the characters telling stories that can be many different things such as stories about depression or just a duck crossing the road and then, animation being for kids yes some animation is made for children but there are also animation companies like adult swim which is made almost entirely of animation but everything on their platform is 18+ meaning it is not for kids. Instead of suing content creators you should have youtube be made for all ages and then parents should be able to set what age range the content should be and content that's not for children should have disclaimers and to make sure it's not a child watching the inappropriate content youtube should have them put in their youtube account password before watching inappropriate content. Sincerely, a concerned civilian.


This is a no go, cant you just stick to youtube kids and no pull anyone else into this

There are many things that are colorful, fast ,and have sound effects that I a young adult like. That being said if and when I do have kids I will not be letting them watch and/or play said things. But seeing how this is going, some of us might want to get some copies of Farebheit 451 and 1984 and hide them.

This is completely stupid. It's not the YouTuber's fault about what kids do. These rules will wipe out a huge population of youtube and no one wants that! Please just listen to the community!

People and Content Creators are quite literally panicking over this and the information here is very vague and has no nuance to it that helps anyone. Please either update this or find a fair and easier compromise as this is going to hurt the Content creators, Not Google/Youtube

Just take the children to Youtube kids and leave our content creators alone. Irresponsible parents should pay the violation penalties for letting their children have access to inappropriate content.

What about "family friendly " content? Example: fishing is not directed at children, but it should be ok to watch a father and son fish together! If the subject matter is family friendly, then having a youth participant in the video shouldn't be an issue, provide language and content are "rated G"

What about gaming channels like Call Of Duty. Dragonball Z relate games, Zombies and horror games. What about trading card games I've Dragonball super, Vanguard, Yugioh, etc.

Hey my videos not made for kid's.i don't wait them on my you tube.if it's possible if they can not put them on my you tube.

FTC, please know there is a such thing as YouTube Kids. Parents can use that.

My videos are suitable for all audiences, what should I do?

Dear FTC,

Would you please clarify:

1) If a channel is about cooking/baking video recipes which include recipes for cup cakes, muffins, cakes, would this fall under "made for kids" (it is definitely made for parents who "might" have kids under 13 who knows)?

2) Suppose if only one or few videos are "made for kids" and not the whole channel? Does entire channel then gets covered by COPPA or only those individual videos directed to kids?

3) What if a baking video is directed to parents to teach them a recipe and also how to involve kids (showing kids actors) in making this recipe... would this be counted as "directed to kids" even though it was actually for parents as recipe involves steps not meant to be done by kids alone.

Thank you!

This blog has information to help channel owners. It says if the content that a channel owner uploads to a platform like YouTube 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.

This is all far too vague. Also who's too say what's for children and whats not? Would Disney movies be counted? Animation, even those targeted for a general or younger audience, can have both adult and younger themes. It mentions stuff like politics and the economy being 'adult' stuff. This is horrible honestly. To call NSFW stuff only for adults is fine, but when other topics are brought in like the economy its questionable what children are being protected from; but to say that adults can't talk about stuff more 'childish' makes me question those that approved this. Do those in favor of this have no 'childish' hobbies? Do they not enjoy bright colors every once in a while? Do they not like fun?

What would a content creator do if his contect contained a children/family videogame, but the language, conversation, and jokes were all made toward an older audience?

I personally think this rule is terrible. How are yt creators going to make money? People make a living off of youtube and the irresponsible kids and parents are causing people to lose their jobs.

Can you please reconsider this rule please? I don't want spend December and Christmas feeling sad that my favorite YouTube channels are gone because of the COPPA rule.

The marking of a single video or channel as "Made for Kids" or "Not Made For Kids" is far too nebulous to be truly effective. There are millions of creators whose content is completely safe for children, but isn't specifically made for them. A much, much better solution would be a multi-tiered system like the MPAA or ESRB ratings systems for film and video games, respectively,or the TV Parental Guidelines system. Even an in-between option of "Safe for kids, but not made for kids" would help things. I operate a channel that hosts advertisements for various businesses, ads that are broadcast both locally and nationally on major television networks. ALL of our content is safe for children, but NONE of it is specifically made for or targeted at children. My channel is marked as not made for children, but what happens if the FTC decides that it is? Do we get fined even though we followed the rules? Again, the rules aren't 100% clear, and that situation isn't addressed at all anywhere in the COPPA documentation.

Ultimately these new COPPA rules seem too quickly drawn up and implemented, and I would suggest the FTC take a bit more time to really make sure any new systems or guidelines that are put into place are cleanly defined, easy to understand, and clearly communicated. This is the only way said rules and guideline will have the desired effect without scaring off and/or damaging creators and channels who don't understand the current rules because they have not been clearly defined.

Hello, I wanted to say that, while I am pleased that you care about the safety of children, it is very worrisome to many Youtubers out there due to the fact that this is a job for them. If this goes through, who knows how many would end up in life. You can't put the blame of those that want to those that want to make entertainment to all ages. I was thinking there should be a better solution so that it's not only protect kids, but content creators themselves. Maybe have something where anyone can make their account, but when doing so, the rules should be very strict regarding age. That way, whoever is making that account won't lie about their age. Plus, if they are below the age of 13, then they won't have to worry about certain ads. In the end, here's hoping there is a way to make things whole lot better for both COPPA and many people on Youtube. Thank you for your time reading this.

Sorry but how’s this gonna work again? The kids most likely use their parents email as THEY ARE NOT OLD ENOUGH to have their own accounts. So by destroying all the content creators you effectively give easy access to children to get inappropriate content because it’s not directed towards them. Think about it.

Well this clears a few things up. I was previously up in arms over how broad a brush COPPA was appearing to paint with. Now that I'm aware people will actually be determining this based on much more concrete metrics than "He said cool, take his money" I'm much more relaxed.

Why u r destroying yourube

This brings very little additional clarity to the original document. As a YouTuber who had made crafts and has a particularly pastel aesthetic this still terrifies me. My content was not created FOR children and the wording above still does not concretely verify that making crafts in my pink room won’t get me fined. Perhaps not going through with this still frighteningly vague update and instead making sure that YouTube’s account system which requires the user to be 13 or older is properly enforced. Or adding that using a YouTube account is neccisary to view any content and that by being on the account any child using their parents account then has parental permission to view targeted ads and allow data collection. Please instead put this on the parents and not youtube creators who are simply trying to be ad friendly and entertaining.

Ultimately the criteria listed is too vague to be useful to content creators. Also much of the criteria listed applies not only to kids but adults as well. A large swath of the adult population plays video games and still enjoys cartoons. There are many artist who use animation despite the substance of the animation being adult in theme. The content creator does not collect the information of their child viewers, but the platform does. Fining them would be unjust. Many of the things used to gain the attention of children such as bright colors or words like fun awesome also gain the attention of adults. Much of the criteria listed shows a complete lack of understanding of the way in which internet culture, content creation, and consumption works. The criteria needs to be heavily refised, reduced, and refined. As most of this does not protect children and only ruins content for older viewers, harms content creators, and protects entities like YouTube using and selling the data they harvest from children.

Please. Please. Please. Just listen to yourselves. I understand you want to make this as safe as possible for kids. But the fact that you are taking literally everything away from people. 98% of the content on YouTube will be “for kids” with the writings that you have put out so far. Everything is colorful, tons of people who play games want their content to be for everyone. BECAUSE IT IS! Adults watch games, animations, unboxings, etc. TOO. so what you are saying is that everything on YouTube will basically go on YouTube kids. Honestly. That really. Really. Shouldn’t be how that works. If you are actually going to go out with all of the things you’ve put out right now, well, you are going to get much love with that. People would appreciate if you just let animators, gaming channels, and other youtubers that LITERALLY have color in them go free. Just do your hardest to block all the bad content in it. My friend is an animator on YouTube, she has worked really hard to get where she is. All the other animators have too. All the gamers have too. Everyone has. And to charge a 42,000 fine for expressing feelings and emotion to adults is actually hecking mad of you all. I’m not saying I disrespect that your doing this but the way that you are bringing it and out and way you are carrying it out is horrible. Thank you.

I think this decision and its implementation should be reconsidered. The criteria for "child-attractive" is too broad and should be removed. It unfairly penalizes content creators in certain categories, like gaming or crafting who may intend their videos for adults, but find that kids may enjoy watching them, too. I also think it is unfair to fine content creators for failing to correctly identify their videos based off this vague criteria. The fine amount is also far too high for the infraction- surely a percentage of revenue from the video would be a more fair penalty. I am an adult Youtube viewer who enjoys craft channels, doll repainting videos, and anime cosplay. The creators I enjoy will be deincentivised to produce this content for me, an adult, as it will either offer little revenue and engagement as a "child-directed" video (even though it is intended to discuss these hobbies as adults, that children might like to see but couldn't participate in at the level discussed), or they run the risk of being fined more than a year's wages to the average American worker for labeling the video as adult directed if some arbitrary interpretation of these vague standards goes against their favor. And every single video would add to their risk. Placing the burden of protecting children's private information onto the content creators is ridiculous and unfair. The companies who mine this information for profit and the parents who allow their children to misuse the adult's social media accounts should be held responsible. Please do not penalize content creators for a mess that was none of their doing. And please do not punish me by pushing the kind of content I enjoy out of this public sphere - I don't have kids, and I'm not making any money online or collecting any information. I just want to watch other adults participate in the hobbies I enjoy... that children might sometimes enjoy watching, too.

This actually violates freedom of speech yknow

The current state of the law is flimsy at best. You need to outline specific details about what people should look for in kids content. The middle ground for things for kids is insane. The same content that has curse words and swears, may also have Mario in it. Mario is a reconizable kid icon but obviously the video isn't for kids. You need to specifiy your laws to a very concise system, or drop it entirely and come up with a sign up with your parents permission to acess youtube. Like an account, so that you cant enter the website without either being 13 or older, or having a parents permission.

Thank you for reading my input, Have a nice day/night/whatever time it is as of reading.


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