YouTube channel owners: Is your content directed to children?

Share This Page

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.

 
 
 

Comments

In my opinion, treating content creators the same as website owners is the wrong approach. A website owner owns the domain as well as everything on the site. The only thing that a content creator 'owns' is the video, and YouTube's TOS already states that they may remove videos if found to be violating the law. In other words, YouTube is a service provided to both content creators and viewers, and the possibility of the FTC fining the creators for wanting to share their passion for Pokemon, Disney, or another 'kid-friendly' property with a general audience comprised of both kids and adults is very concerning to me for personal reasons.

As a graphic designer, I have portfolio pieces on YouTube that could be considered kid-friendly. I cannot afford to restrict who views them, as a potential employer might not be able to view these videos due to how YouTube is handling the content restrictions. I understand that the FTC is not directly involved in how YouTube enforces COPPA regulations, but if I cannot share my portfolio videos on a worldwide platform like YouTube, it will negatively impact my career. There are others like me who rely on YouTube and other online platforms to share our art with the world, and our art often cannot be boxed in to just 'kid-friendly' or 'adults-only'. I cannot afford to pay a large fine if my videos are found in violation of COPPA. Please review and expand on COPPA so that creators like myself will not be negatively impacted.

The Six-Step Compliance Plan for Your Business says you must comply with COPPA if:

Your website or online service is directed to children under 13 and you collect personal information from them.

OR

Your website or online service is directed to children under 13 and you let others collect personal information from them.

OR

Your website or online service is directed to a general audience, but you have actual knowledge that you collect personal information from children under 13.

OR

Your company runs an ad network or plug-in, for example, and you have actual knowledge that you collect personal information from users of a website or service directed to children under 13.

While the reason for COPPA restricting YouTube is valid, COPPA is very broad as it doesn't allow for much of anything. COPPA does not allow for bright colors which are seen in much of adult content. COPPA also does not allow for many subject matters that are discussed by many adults such as sports and pets. In general, COPPA is a good idea however COPPA enacting on YouTube will not only remove all content for kids, but it will also remove most adult content as well. Combined with YouTube's demonetization rules, YouTube will be left with little to no content being able to be created. Not to mention that COPPA has such a large fine for incompliance that YouTube will be destroyed and the people with jobs making videos on YouTube will have to leave and YouTube itself is in massive jeopardy of crashing itself

This is sad...these rules are nothing more then clueless, overly blown with censorship, and does way more harm then good for content creators. This destroys YouTube no doubt and anyone else thats involved. Youtubers have the right to speak out about this and they have the right to explain what means to their channels and these rules are just making everything bland and silences them.

I implore to the FTC to DO NOT allow these rules to be implemented . The children is all under parents guidance and SHOULD be supervised by parents, not by YouTube to monitor and watch their kids with boring content or dull ideas. Parents that complain about YouTube, doesn’t know how to raise their kids right. Leave YouTube alone, and DO NOT IMPLIMENT these COPPA rules next year...period!

If a channel on youtube is making gaming videos on said channel but the games contain fictional violence, or if the games are explicitly rated 18+ due to gore, nudity or disturbing imagery, is it still deemed for children?

If the video is like a kid game but with Swearing in it and a and a swear in the title will I still be fined if i say not kid friendly

Dear Mr. Simons, I am commenting on this issue because I have been brought on by others suggesting that I should.

Based upon what I've read, heard and observed for myself, I feel that there has been much miscommunication, as so many are panicked while under the notion that they will lose any and all livelihood based upon fears that were provoked by the ambiguity of how COPPA's laws are currently written.

I am here in hopes of aiding the solution, or perhaps even compromise in this crisis, as it personally affects me as a content creator myself.

Giving anyone I encounter the benefit of the doubt, I did not prejudge COPPA as malicious, such as countless others seem to have labeled it. Presented with the ultimate goal of supposedly protecting children's information from being collected, this is a very serious subject that I also feel needs to be dealt with.

However, the currently presented "solution" that you have provided is dangerous for an infinite amount of YouTube users as they work countless hours in production for each video posted, not to mention the actual conceptualization of them, and with almost complete uncertainty of where their income will be coming from in these depressing times of unemployment rates rising, and the ever present threat of inflation rearing its ugly head from many individuals demanding higher minimum wage rates inspired by pseudo-intellectual knowledge, YouTube is seemingly the only option to do this and within the painstaking process of content production, the revenue earned from it all practically goes to waste as that is also so financially underwhelming, more funds went into making the actual video than profits resulted in the aftermath.

These are human beings who struggle from a societal standpoint who are cheated out of daily opportunity for "real jobs" and in place of it, is raw passion in what they do on YouTube. To have their own platform stripped away from them is depressing as it is disgusting to imagine how the higher-ups seemingly do not care about this and instead wish to forward dangerous proceedings that can and will affect them in every way possible.

In hopeful solution, YouTube had created the side-platform YouTube Kids – a section of the site made specifically for younger audiences. Unfortunately, this has apparently failed since COPPA is getting more involved with the running of the main site.

YouTube has an internal rating system for channels, differentiating them by types of content and which viewing audience is their age average depending on the contents of the users' typical uploads.

Now, I will present my solutions for the issue of preventing children's exposure to mature content and advertisements in the following:

>For YouTube's internal rating system to become publicized and for each channel to have the requirement of displaying their specific rating on their accounts. To take it a step further, they should also be required to re-upload videos displaying their rating at the beginning, as to inform their audience if they should expect mature content that could run advertisements of the uploader's merchandise at some point in the video.

>For YouTube to provide content creators the option of editing their videos post-upload.
*Elaboration: For users to replace video files. This would further help them with the above solution*

>For YouTube to not feature mature content or promotion of products in the Trending section.
*Elaboration: Promotion of products would include makeup/toy/food/etc. reviews. Essentially, anything that would count as advertisement for either oneself or corporate entities*

Thank you for taking the time to read this, and please consider my comment – I do not want YouTubers to suffer, myself included.

The amount this fine could be breaks the 8th amendment, and we need a choice for content that could be enjoyed by everyone.

Please for the love of god tone down the fine it is legit $35,000 that is enough to end families businesses overnight make it 100 or 200 dollars
Y’know something actually PAYABLE and will not not end families for basically nothing

Instead of putting this pressure on YouTubers, thanks to YouTube's own mistake, wouldn't it make sense to just have an age gate on the site?
So you type YouTube into the search bar and before you use the site you have to verify your age, under 13''s getting redirected automatically to YouTube kid's. This would save a lot of channels and a lot of concern on the site. Especially for someone like me who now ha's inaccessible channels and videos meaning I cannot physically make the changes or remove the videos to comply. Please think about the lives you will ruin with these fines. I can guarantee it will be the biggest cause of homelessness in 2020 if you go through with this.

I understand the need to protect children from targeted marketing. Instead of lumping all the channels into two categories why not include a general audience section. There are many content creators that have a general audience. I would hate to see these channels disappear because of this law. I am in my forties and I watch dog channels (mostly Siberian Huskies), gaming channels, etc. What about the animal rescue channels? YouTube is a platform rescue centers use to bring awareness to homeless & discarded pets. Since these rescue centers are not government funded, they need all the revenue they can acquire to further help these animals.

Hello,

I have what I think is a good idea.

There are many people who have uploaded to youtube in the past, but who may not be able to access their old accounts for whatever reason like being unsuccessful at recovery if they forgot their associated log in information like user names, password, e-mail.

I think it would be a smart idea for the FTC to keep this in mind, when considering what action to take in the event that action is taken.

I would hope that in cases like this, the FTC could work together with a defendant to get the content in question removed, because the defendants alone are not able to.

At the very least, I believe this should be a factor when deciding what legal action to take.

What a child does, or does not watch, on the Internet is the responsibility of parents - not the government. Trying to legislatively protect children from content and data collection severely damages free speech while doing very little to protect children.

Do you really think this is appropriate to make people pay 47,000$ for a violation. I mean no one simply has 47,000$ laying on my desk. Also does it even make sense to have animators put their animations as Kkid friendly if there is drinking, drugs, and inappropriate things in there I think Not.

I have an idea to make the YouTube site better. The website or app can be completely unusable unless the user is logged into an account. If the user is under the age of 13, then it won't let the user in. There could also be an option to login to the YouTube Kids site for users under the age of 13 and an option to login if the user is 13+. This is just an idea I had. If Google acknowledges this idea instead of marking content and channels for kids, then YouTube will hopefully be a better place.

What does..."age of models" mean? is that people? Or is that the age a person starts building models? New model kits vs. old model kits? What kind of "subject matter"/ What kind of "music"/ What kind of CGI can be used? Its a shame you can't make a clear statement on any thing, or supply an example of what you think you are talking about. A yes or no flowchart would be nice.

I live in a rural area that is centered on hunting, fishing and retirement. I want to see people get outdoors and having fun. RC vehicles( trucks, cars, boats, planes, and drones), hiking, and hopefully some camping around our beautiful state of Missouri, is what we are about. I feel I'm adult centered content but kid friendly.

Umm. I’m a GachaTuber and I don’t know if my content is made for kids. Some videos have cursing and some have fire and death. Plz help me understand what is my channel. I am very confused bc I made videos to release stress. I didn’t make if for kids to be honest...

your new law(COPPA LAW) is losing a lot of channel

Right. I get that there are some people out there who will lie about their age just to watch a simple video that may or may not be directed at them. But what about the animators? I myself am part of the animation meme community, so what about us? Do we break the rules because of bright colours and characters that might appeal to the people who shouldn't even be on a 13+ site? Theres a reason why YouTube kids exists, and it's for this reason. Do you just go look at thumbnails of videos and say: "Oh, well this breaks our rules. Lawsuit!" without even knowing if it has child unfriendly material within it? You would just be taking everyones liberties with this act, and everyone's creativity. If you want to stop children under 13 from watching YouTube, don't allow them to lie. Maybe make a centralized system of account making where you have to show proof of some sort that they are their said age. Like a portion of their birth certificate or something of the like, because taking out content that people have worked on for what could span for months because of the simple fact that a careless parent let their underaged child on the internet doesn't seem right. I don't know if the team behind this will even try to acknowledge this comment but at least I tried. Have a nice day.

There should be some middle ground. I’m gonna explain this by using an example. For example, Jacksepticye and Pewdiepie make gaming videos. At first by looking at the thumbnails of the videos you would think, oh this is for kids, but that’s not the case. Jack for example, swear in those gaming videos. His language is considered for adults, but the video isn’t! Same with Pewdiepie! He plays Minecraft, but some of the things he does and says in those videos, aren’t meant for kids under 13. Well, most of his audience are teens and adults, but yet those videos are likely gonna be marked for kids, even though it’s not really a video targeted for little kids! Most of his videos btw are targeted towards a large fan base of kids all ages, but that’s besides the point. Just by looking at the thumbnails of these videos they can be marked for kids! Which is dumb! Also Minecraft can be enjoyed by all ages, and is made for all ages, so that should be considered the middle ground videos! The point is, are they gonna mark those videos, for kids, since video-games are considered for kids? Or are they gonna be considered for adults, since there swearing in it? If these videos are marked for kids, it clearly means that all Coppa did was look at the thumbnails, or they watched the videos, and are completely stupid. Clearly there needs to be a middle ground, where the videos are considered for kids, and adults, bc theres not just 2 different types of videos. I hope this all makes sense.

We definitely want our children to be safe on line. It should be our number one priority but shutting down the art and craft channels is not the way to go. YouTube already has a channel for children alone. Please specify the rules better and dont take away our favorite channels and most of all our favorite Youtubers that worked hard to make their channels what they are today. We love leaving comments and being able to get responses ,from them. That's one of the reasons we subscribe to the channels we watch. Please make the COPPA rules more clear. And dont penalize those poor people some of them or most of them making a living from their channels because you couldn't make the rules better. Please re consider and dont take our drawing and crafting channels our haul channels and DIY channels off. I am a loyal fan and subscribe to a lot of channels here on YouTube. Please re consider because if you dont then I guess well just have to do something drastic like boycotting YouTube and we dont want things to get nasty and ugly. We love our Youtubers. Please Help all of them by being fair. Thank you. G.R Worcester Mass

I'm planning to make animated videos intended definitely not for kids ... Do I have to worry about being covered. .. also will viewer discretion work ?

I was 1,000 hits away from monetizing the videos on my small channel if I had wanted. However, I have deleted them all because the ridiculously vague "COPPA rules" were not worth my time and worry. I DO understand the need for the COPPA laws but I have concerns/questions: 1) Instead of child-directed or not, why can't the movie rating system be used (i.e. PG, to X-rated) to classify the videos that content creators post to YouTube? 2) How does YouTube get away with dumping the responsibility of inappropriate advertising onto the content creators when it is YouTube's programming that needs adjustment. 3) Why are content creators being fined and held responsible for videos that unattended children may see (do porn movie producers get fined if a child sees one of their nasty flicks)? I hope this situation can be worked out as soon as possible. I am subscribed to dozens of fantastic inspiring content creators that may lose their livelihood if they are fined, can no longer monetize their channels, or give up out of frustration as I did.

I have a number of questions.

1. When did the federal government get in the business of evaluating whether works of art, in this case, videos, are targeted at one audience or another? And in making such a determination -- presumably without giving the content creator due process to make a case to the contrary -- are you not in danger of violating that content creator's First Amendment free speech rights?

2. YouTube has elected to address this settlement by giving content creators/channel owners a binary choice for self-designating the content of their videos as "made for kids" or "not made for kids." Yet the COPPA law clearly makes an exception for "mixed audience" videos, or videos that may have appeal to children, but are made for a broader audience. What is the best practice for such content creators? Should they self-designate such videos as "made for kids," thereby forfeiting all the benefits (including upwards of 90 percent of the monetization potential) of being a content creator? Or should they designate their "mixed audience" videos as "not for kids," thereby interpreting the language of YouTube's question as "not EXCLUSIVELY for kids."

3. Has the FTC considered the law of unintended consequences here? I mean, all the content creators I know, and the ones who have posted videos about the new COPPA enforcement in the wake of the YouTube settlement have made it pretty clear that they're most likely just going to stop making content. In many cases, these are content creators who fell under that "mixed audience" definition and were not specifically gearing their content toward kids exclusively. Rather, they were creating high-quality, family-friendly content that kids enjoyed, but was equally enjoyed by parents and teenagers and others. Has the FTC considered that by scaring off a lot of these content creators, what they're going to leave in their wake is a vast wasteland of child-inappropriate content on YouTube. And while YouTube has done NOTHING to prevent under 13 age kids from watching YouTube content, they've simply driven off many creators who were making child-appropriate content. This action seems incredibly short-sighted, foolish and not at all well-thought-out.

4. If a content creator/channel operator self-designates his/her content as "not for kids" on the assumption that it falls under the "mixed audience exception" and the FTC deems the content to be "child directed," on what authority does the FTC make such a judgement? I would like to see the law that states the FTC has been granted the authority to deem third-party content to be directed at one audience over another. Where, exactly, is that articulated in the FTC charter?

5. If the FTC does step in and make a determination that a content creator has self-designated his content as "not for kids" on the belief that his content is, in fact, a "mixed audience exception," but the FTC disagrees, how will that play out? Will the content creator hear from the FTC via email? Will he receive due process? Or will YouTube just shut him down, again, without due process? Quite frankly, given that the worst possible outcome for the child viewer is that he or she might see a directed commercial, which happens about 12 times per minute on network and local television, this seems incredibly heavy-handed for what amounts to a minor violation. Wouldn't the nation's children be better served by having their PARENTS do the parenting in this country rather than having a federal government agency try to act as the nation's nanny parent?

I would like a little more clarification on what is "child content." Many video games are not kid-friendly or kid geared. Perhaps mandating a category of "general audiences" would be a great way to set people at ease. Please consider this. Thank you.

Video/Computer Games, in regards to content creators, should be completely excluded from COPPA. The ESRB already handles the rating of video games by taking the time to actually play them to determine who the game is for.
The ESRB also uses an open ended rating system for the friendlier games, such as the ratings E (Everyone) and E10+ (Everyone aged 10 and older) because the ESRB understands that even adults can enjoy child friendly video games.
Content creators don't play the video games they do in order to prey on children, they do it because they themselves love to play those video games and want to share their experience with others.

As an extra note, the FTC itself has already praised the ESRB for the work they do calling them the "strongest self-regulatory organization in the entertainment sector."

Would Gacha Life be counted as children's content? If you could reply that would be nice!

This is terrible!!!

Are you really gonna destroy youtube I understand you want to make YouTube better but what your doing is actually insane but at least make the people at YouTube change there minds about what's gonna happen in 2020

Please do not make this rule permanent it is not the creators job to look out for children under the age of 18, but it is the parents job. Please don't make you tube like this.

YouTube may be a large company but that doesn’t give you the right to shut down people who are getting paid for this but can’t

We spend so much time on animations and everything it can take up to a year. Please add a key that could say 13+ As they are not considered children at least. Also I can’t afford the fines so that’s another problem.

Why is it so vague?! I literally understand only some part of it...

I don’t think this is fair. You’re destroying people’s job by saying “ tHiS nEeDs tO bE kId FrIeNdLy “ . As mat pat said. “ Youtube is more focused on the more mature audience “ . So maybe not use Coppa of FTC on YouTube , I don’t think kids or teens or higher would like to see their favorite youtubers content changed to follow the rules of Coppa,or I dont think they’ll like to see that their favorite YouTubers channel is gone because of Coppa

Please reconsider or at least clarify what you all are saying. It would mean a lot as a entertainment channel

My videos are only short clips of places or events I've seen or been to. Definitely nothing that would interest children.

This law makes no sense of content providers. I use my channel primarily to relay and save things for high school classroom. How can I control what a child will watch? Isn’t that a parent responsibility? Why would I be penalized? I don’t collect data. I have no way to collect data. As per usual the solution to a real problem is not this current Coppa law.

I am very confused about this. As a Youtuber, I understand that we need simple rules to follow. If I'm not able to upload my videos, this may lead me to deleting my Channel

Where is the parent's responsibility in all of this discussion?

If a parent is paying for content on a service for themselves or their child, great, identify the account as a child account and have these regulations and companies should adhere to them. If creator's are using a service like YouTube to provide content, then it should be Google's responsibility to understand a child is watching and take appropriate action to not target them with ads. The creator can help Google by specifying if they specifically mean their content to be geared towards kids, but otherwise there should be NO burden or threat of legal action placed on a creator providing their intellectual content.

I agree. There are lots of ways that Google could do this without Shifting the responsibility. For starters, Google could allow sub accounts that would allow parents to control what type of information is collected about them. Google could also be required to not use tracking for any advertisement that is directed at children. That part should be a no-brainer. If the issue is that ads are directed at children then don't worry about if the video is directed at children, worried about the ad being directed at children. Just disable tracking on that type of AD. It's that simple. The only remaining issue are the comments, which again could be solved with sub accounts. A parent would have to explicitly choose to allow the child to comment on videos which would completely make the entire YouTube sight compliant with Coppa without having to put all the content creators through this mess.

This rule has many faults, I believe that the FTC does not understand the difference between kid-friendly, being appropriate for kids, and kid-oriented, being exciting for kids. There are many YouTube channels that do kid friendly activities, such as playing a video game, but maybe the commentary doesn’t appeal to children. These YouTubers are put in a hard position, because they can either say Not Made for Kids, and get fined for incorrect categorization, or say Made for Kids, and receive less ad revenue, and viewers will receive no notifications. This is extremely problematic for YouTubers who make a living off of YouTube. Also, I would like to make it clear that YouTube kids is a thing, and kids can fake their age, making YouTube’s child security weak in the first place. My proposal is, since the rule in question is about children’s privacy, fining channels should be only implemented for marking non kid friendly videos as kid friendly, therefore exposing kids to obscene content. Although, the FTC should also make a way to mark videos as non kid oriented, when YouTubers create content friendly to kids, but not that kids would find interesting, therefore not receiving a fine for mislabeling. I hope these changes can be implemented to make YouTube a better site all around.

Every content creator on YouTuber uses what the FTC considers child friendly.
However our channels are not all aimed at children their aimed at general audiences.
And the 90% payment decrease will put us in bankruptcy especially if you Sue us for $42,530 per video this new COPPA law is unreasonable as well as

Really? You're pushing COPPA out like this? This isn't finished being revised and improved, and the fact that COPPA isn't finished being revised shows how much you REALLY don't understand content creation. Kill this project or narrow down the options towards a simple solution of a choice for content creators EXAMPLE THAT YOU SHOULD FOLLOW AND USE: Content creators are required to choice "for children" or "not for children" before uploading videos and other content. Along side this option a set of rules for the "for children" option will be listed for content creators to follow. In doing this, the content will be shown to children while all other videos will not be.

FTC, Thank you for the this letter and the directions to review pages 10-14 of the complaint.

To folks posting: if you haven't read it, go read it now and think about commonalities in the complaints listed (Hint key words are "About " and "YouTube Kids")

FTC, There is clearly a lot of vagueness in "the subject matter" criteria that is causing confusion among content producers, can you provide additional links to promulgated regulations or court findings (beyond the YouTube Google agreement) that content generators could review to better understand what constitutes, in the FTC's opinion, "child-directed subject matter?" Thank you.

I am not against this I just want to say I don’t know how to accept this. Since I don’t know how it’s not letting me upload. If you could tell me how to I would and I could upload again.

I feel that there are a lot of videos that don't fall into a particular category. I feel the new rules need to be revised and clarified.

This will destroy the gaming side, review side, and even some of the comedy of Youtube. People will be too afraid to upload, and those who do will go bankrupt because of fines. Youtube as a whole will go bankrupt, so please, don't do this. Or at least change the rules so they allow people to still profit from youtube.

What happens if adults like (For example) watching people play an online dressing game because it is funny to watch?

I have a modest YouTube channel with several thousand subscribers. I’ve been making a series of episodic videos with serious, dramatic, adult plotlines, including crime, murder and revenge as story elements, similar to what you might expect from an adult-oriented prime time television drama, and with the highest production values I can achieve. But I exclusively use footage from specific video games to create the visuals that dramatize the story along with the dialogue (because I don’t have even remotely the capacity to shoot it as live video). So what are my options after these YouTube/COPPA changes? If I state (correctly) that my videos are not for children, the FTC can still decide the videos are child-directed because of the inclusion of video game visual content, and proceed to fine me on that basis. Conversely, I certainly can’t and wouldn’t want to represent my videos as being for kids, for the reasons I have explained above ... attempting to make such a claim would rightly get my channel deleted at a bare minimum. On one hand the FTC website says that they acknowledge there is such a thing as “animation” that is for adults or a mixed audience, but the same has not been stated about “video games”; in fact I have seen “video games” pointed to as blanket evidence of content being kid-directed. And then there’s the FTC themselves in their press conference talking about YouTube content creators in the kind of disparaging terms one would normally expect to be reserved for pornographers, which does not inspire me to just trust that I would be treated fairly, no matter what I do or what the FTC website vaguely suggests. As such, I’ve concluded that the only completely safe option for me is to delete my existing videos, stop making any more such videos, and effectively terminate my channel before 1/1/20. I assume it was the FTC’s intention here to suppress artistic endeavors, because that’s the effect they are having on me.

Craft channels and artist demonstrations should not be handled as outlined above. These channels directed at adults should NOT be penalized for child viewers even if child viewers use a parental account.

Sad example of misguided FTC regs.

Pages

Add new comment

Comment Policy

Privacy Act Statement

It is your choice whether to submit a comment. If you do, you must create a user name, or we will not post your comment. The Federal Trade Commission Act authorizes this information collection for purposes of managing online comments. Comments and user names are part of the Federal Trade Commission’s (FTC) public records system (PDF), and user names also are part of the FTC’s computer user records system (PDF). We may routinely use these records as described in the FTC’s Privacy Act system notices. For more information on how the FTC handles information that we collect, please read our privacy policy.