TikTok first outpaced YouTube as Gen Z’s and Gen Alpha’s go-to video platform in 2020, and it remains so in July 2022. That has made the platform not just a competitive target for YouTube but also a focal point of concern for researchers who report that TikTok regularly presents content that promotes unhealthy eating habits. Those findings are a problem for brand marketers who sell snacks and fast food and leverage the platform’s popularity to introduce products to new audiences.

Marketing To Children Without Marketing To Children: Rules, Research And Controversy

While COPPA imposes strict requirements on how advertisers can target children under 13 and what platforms can do with their data, TikTok, like YouTube, states that users must be 13 or over to log in and use the site. So now TikTok, just like its forebear YouTube—which has faced litigation from nonprofits and parents’ advocacy groups over children’s ability to access the site and the site’s alleged collection of data on their viewing habits—is under scrutiny.

TikTok, like YouTube, allows anyone to watch videos without registering. While you must affirm that you are over 13 to sign up for an account, there’s no way to stop a teen’s younger sibling from watching over their shoulder or simply using their device. That means that non-explicit content available to adults is open to children, and brand marketers who engage young adult influencers to issue challenges or create content with their products, healthy or not, aren’t marketing to kids directly, and therefore not in violation of COPPA. That said, there is plenty of evidence that kids are watching and engaging with content designed to promote fast food and snack brands with high fat, salt and sugar content.

According to a report issued by BMJ Global Health:

“Unhealthy food and non-alcoholic beverage brands are using TikTok to market brands and products via their accounts and to encourage users to create and share their content that features branding and product images.” The report stated that some brands were marketing their products to encourage users to purchase and consume products for challenges.

“The most common marketing strategies were branding (87% of videos), product images (85%), engagement (31%) and celebrities/influencers (25%). Engagement included the instigation of branded hashtag challenges that encouraged creation of user-generated content featuring brands’ products, brands’ videos and/or branded effects. The total collective views of user-generated content from single challenges ranged from 12.7 million to 107.9 billion. Of a sample of 626 brand-relevant videos generated in response to these challenges, 96% featured branding, 68% product images and 41% branded effects. Most portrayed a positive (73%) or neutral/unclear (25%) sentiment, with few negative (3%).”

TikTok’s Privilege Is Its Ability To Engage—It’s Also Marketers’ Biggest Challenge

Of course, promoting products is what brand marketers do; they attempt to drive engagement in creative ways. And, like platforms built around user-generated content, brand marketers try to avoid breaking the law. For example, TikTok and YouTube require users to register to post videos but not to watch them, and there’s no way to vet who is behind an email address—unless some form of digital identity verification system is introduced that limits access to specific types of content, like porn. But that may not work, even if such a system was technically feasible. Ever met a teen who’s seen content intended for an 18+ audience? Ever met a teen who’s tasted a beer? It’s unlikely that fast food or salty snack-related content will ever be considered adult-only since neither can be considered age-restricted products.

There is also the matter of TikTok’s raw power to engage users. A familiar example of TikTok’s influence is that, at one point, Jennifer Lopez posted the same video on Twitter and TikTok. Her TikTok video gained 71 million views from 5 million followers, and her Twitter video received only 2 million views from 45 million followers.

TikTok makes sense for brand marketers, but it also needs to make ethical sense.

Here is a list of resources from the ANA regarding best practices for marketing on platforms with younger audiences:

From the FTC:

From the ANA: