Ryan and his parents have been slapped with a complaint filed with the Federal Trade Commission over his sponsored content.

The mega-popular kids YouTube channel Ryan ToysReview has been accused of tricking preschoolers into watching ads in a complaint filed with the Federal Trade Commission by a consumer watchdog. The channel stars Ryan, a 7-year-old who has been YouTubing since 2015. His account is run by his parents, who began filming their son playing with and unboxing toys when he was a toddler. Ryan ToysReview has since grown into a media empire. The original channel has more than 21 million subscribers and his videos have been viewed more than 31 billion times. Ryan now stars in a show on Nick Jr. called Ryan’s Mystery Playdate, in addition to his channel. He has scored advertising deals with Colgate, Carl’s Jr., and Walmart. But according to consumer watchdog Truth in Advertising, Ryan and his parents have been “deceiving millions of young children” on a “daily basis” by taking these ad deals but not disclosing them properly. The complaint identifies Ryan’s parents as Shion and Kieu-Loan Guan. However, a spokesperson for the family identified the couple to BuzzFeed News as Shion and Loann Kaji. In response to the complaint, Shion Kaji told BuzzFeed News in a statement that the family “strictly follow[s] all platforms’ terms of service and all existing laws and regulations, including advertising disclosure requirements.”

In a complaint filed with the Federal Trade Commission (FTC) last week, Truth in Advertising said that Ryan’s channel “deceptively promotes a multitude of products to millions of preschool-aged children in violation of FTC law.” Ryan’s channel is doing so, the complaint alleges, by weaving in sponsored content seamlessly with the rest of his antics. The watchdog gave examples of two videos on the channel that feature Ryan pretending to serve and make toy food in a play kitchen. While one, the watchdog says, seems to not be sponsored, the other is an ad for Carl’s Jr., aka Hardee’s. “Unfortunately, it is often difficult to discern the innocent (or sometimes not so innocent) antics in Ryan ToysReview videos from the sponsored content,” Truth in Advertising claims. “And for preschoolers, it is impossible to discern the difference.”

The complaint says that while an adult would be able to tell that most of Ryan’s sponsored videos are ads, a child likely would not be able to. Take the below video as an example. While the video does feature a voiceover that says Ryan has “teamed up with Colgate” and Colgate branding, there is no ad break that designates it as a commercial.

Truth in Advertising said that because the disclosures are woven into the video, it can be hard for kids to recognize they are being sold a product. “The perceptual cues present in television programming that allow five year olds to

identify ads are completely lacking in YouTube videos that natively embed sponsored content within the program, such as Ryan ToysReview videos do,” it wrote. “Thus, it is not surprising that preschoolers do not realize that they are being marketed to in these online settings.”

Truth in Advertising concludes in its complaint that because the videos primarily are marketed to children, Ryan’s channel is violating FTC law. That law states that ads “must be clearly and conspicuously disclosed in a manner that will be easily understood by the intended audience.” “In this case, the audience is unable to understand what advertising is and cannot even identify obvious commercials,” the complaint reads. “Thus, the company’s native advertising violates FTC law.” In the statement, Ryan’s father said the family is supportive of any efforts by regulators to create new “ground rules to protect both viewers and creators” as they see fit. “The well-being of our viewers is always our top priority. Creating content that is safe and appropriate for our young viewers and their families is very important to us,” he said.