Teen Influencers, Free Skincare and a Legal Grey Zone: How Brands Are Marketing Beauty to Children

Key Highlights
Introduction
How brands recruit young creators and why the practice proliferates
What regulators are investigating and the legal frameworks at play
Health risks and dermatologists’ warnings: what young skin needs — and what it doesn't
Voices from young creators and parents: agency, skill-building and concern
The economics of youth influencer programmes: unpaid labour, gifting and points systems
Why current child-protection laws fall short for online creators
Brand responsibilities: what ethical practice looks like
Policy options and regulatory reform proposals
Practical steps for parents and young creators
Real-world analogues: where regulation has adapted and where it lagged
How platforms can contribute: tools, enforcement and transparency
Balancing agency and protection: ethical considerations
What to watch next: signals for regulators, brands and consumers
FAQ

Key Highlights

Major beauty brands and smaller youth-focused lines are enlisting minors as ambassadors, sending products and event invites in exchange for promotional content; regulators in Italy have opened probes into whether this amounts to covert marketing to children.
Legal protections for child performers often do not apply to online influencers, creating gaps around working hours, consent, payment and safety; dermatologists warn many products marketed to young people are unnecessary and sometimes harmful.
Parents, brands and regulators are navigating conflicting incentives: commercial reach, young creators’ agency and skill-building, and the need for clearer rules and stronger duty-of-care frameworks.

Introduction

A string of unboxing videos on TikTok makes the practice look ordinary: a teenager opens a branded box, thanks the company, and films a short clip describing products she received. For viewers, these clips can feel like authentic peer recommendations. For brands, they are a cost-effective way to reach niche audiences. For regulators and child-health experts, they raise acute questions about whether commercial relationships are being built with people too young to understand the implications.

European authorities have moved from concern to investigation. Italy’s competition watchdog has launched inquiries into global companies after seeing young influencers promote skincare and cosmetics to followers who are themselves minors. Across markets, youth-oriented brands run ambassador programmes that explicitly welcome creators under 18, offering free products, points systems and early access to launches. The arrangements range from informal product seeding to structured tasks that resemble employment, but the laws developed to protect child actors and models rarely extend to creators working on social platforms.

This piece examines how brands recruit minors, what regulators and legal experts say about the risks, what dermatologists caution against, and how parents and young creators are responding. It also suggests practical steps brands and policymakers can take to reconcile young people’s participation in digital culture with meaningful safeguards.

How brands recruit young creators and why the practice proliferates

The mechanics are simple and scalable. Brands identify teens with social followings—sometimes called "micro-influencers"—and invite them to join ambassador programmes. Promises vary: free monthly PR packages, early access to product drops, event invitations, and “points” exchangeable for merchandise. Tasks can be as minimal as liking and sharing content, or as involved as producing videos, attending retail events, handing out samples and conducting street interviews.

Why brands favour this model:

Authenticity: Young creators communicate in the idioms of their peers, producing content that often performs better with teen audiences than polished celebrity endorsements.
Cost efficiency: Sending products or offering early access is less expensive than paid campaigns.
Community building: Ambassadors generate ongoing content over time, creating sustained brand presence among youth cohorts.
Algorithmic reach: Frequent content from many micro-accounts feeds algorithms in ways that amplify brand visibility.

The source material highlights specific companies. Luxury group LVMH, which owns Sephora and Benefit, became the subject of an Italian Competition Authority investigation after campaigns appeared to use young creators to market products to minors. Youth-focused brands such as Evereden and Bubble have programmes that either set an explicit age floor at 16 or leave public age thresholds vague, while still engaging creators who appear to be well under 18.

Programmes often rely on parental consent forms for under-18 participants, but the reliance on consent does not resolve broader questions about whether the young person is being exploited, whether they are exposed to inappropriate products, or whether they understand advertising responsibilities.

What regulators are investigating and the legal frameworks at play

Regulatory scrutiny is increasing along two primary vectors: consumer protection and competition/marketing law. In Italy, the Autorità Garante della Concorrenza e del Mercato (AGCM) is probing whether brands failed to make clear that certain cosmetics were not intended for children, while simultaneously encouraging purchases via covert marketing strategies that use minors.

Key legal and regulatory elements in play:

Advertising rules: In most jurisdictions, influencer advertising must be clearly labelled. The UK’s Advertising Standards Authority (ASA) insists that sponsored content is identifiable and that merely listing an ambassador relationship in a bio is insufficient. Similar principles apply under the Federal Trade Commission (FTC) in the United States and comparable bodies elsewhere.
Child performer legislation: Laws that regulate working hours, conditions and protections for child actors and models typically do not cover social-media creators. Those laws are triggered by classification as a child performer or employee, which may not be apparent in ad-hoc influencer arrangements.
Online safety and child protection: Legislative instruments designed to protect minors online often focus on consumers rather than creators. For example, protections under the UK’s Online Safety Act and comparable statutes do not automatically extend to children producing commercial content.
Cross-border complications: Much of influencer marketing operates transnationally. US-based terms or programmes that permit minors to participate under parental consent can be accessed by teens in other jurisdictions, complicating enforcement of local protections.

Legal experts note that whether an influencer arrangement amounts to employment depends on regularity, structure and remuneration. Gifts, points, and products can legally count as remuneration, meaning that activities performed repeatedly and in a structured way may trigger employment protections. Yet many brands operate through informal contracts or parent-signed agreements that skirt or at least ambiguate such determinations.

Regulators face practical enforcement challenges. Influencer disclosures are easy to sidestep, and brands sometimes embed promotional tasks within broader ambassador schemes, blurring the line between fan engagement and commercial obligation. The result: authorities must decide whether to treat these arrangements as covert marketing targeted at minors, exploitative youth labour, or simply novel forms of youth culture.

Health risks and dermatologists’ warnings: what young skin needs — and what it doesn't

Skincare for children should be straightforward: gentle cleansing, sun protection, and attention to any specific pediatric dermatological conditions. Many dermatologists caution strongly against the use of active anti-ageing compounds, exfoliants, and prescription-strength actives on young skin.

Problematic trends observed on social platforms:

Promotion and normalisation of retinoids among teenagers as young as 10. Retinols and stronger prescription retinoids increase skin cell turnover and can cause irritation, photosensitivity and long-term damage if used incorrectly or without medical supervision.
Overuse of chemical exfoliants and acids, which can compromise the skin barrier and lead to chronic sensitivity, especially in adolescents whose skin is still developing.
Misapplied anti-ageing rhetoric: Products designed to treat signs of aging are unnecessary for most adolescents and can encourage anxiety about appearance at formative ages.

Brands sometimes fail to make safe usage guidance prominent, or they send actives to creators without adequate screening. The Guardian’s source describes an instance in which a brand sent retinols to a teenager who had to decline using them. Bubble says it conducts clinical safety testing for consumers aged eight and up for products it recommends for younger users and employs a pediatric dermatologist on its advisory board. That stands as an example of higher-standard practice, but such rigour is not universal.

Pediatric dermatologists recommend:

Avoiding retinoids and strong actives for children and younger teenagers unless prescribed for a specific medical condition.
Emphasising sunscreen and gentle cleansers.
Using products designed and clinically tested for younger skin when necessary.
Consulting a pediatric dermatologist before introducing new active ingredients.

These clinical cautions intersect with commercial incentives. Active ingredients drive sales and social-media "trends" because they create visible short-term change, which is appealing for platform content. This creates conflict: the most shareable content may not be the safest for young users.

Voices from young creators and parents: agency, skill-building and concern

Young creators often describe their participation in brand programmes as positive, citing confidence, skill acquisition, and opportunities for visibility. One 16-year-old in the source material described content creation as a space of self-expression that helped her find a voice. Her mother highlighted practical benefits: improved communication skills, time management, media literacy, and exposure to professional contexts like events.

But benefits coexist with costs. Parents reported logistical burdens—paying upfront for travel and seeking reimbursement—and tensions about time spent on content creation versus schoolwork. One parent explicitly turned down an invitation when the event's demands conflicted with exam preparation.

Common themes among creators and parents:

Mixed remuneration: Payment is sporadic and often in-kind. One teen reported being paid £100 for a video once; most work earned products rather than cash.
Inconsistent transparency: Some brands require parental consent but still delegate duty-of-care expectations to parents.
Uneven enforcement of age policies: Brands may change ambassador-age thresholds, but previously recruited minors remain in programmes.
Pride and exploitation: Parents and teens often weigh the pride and developmental gains against the risk of normalising unpaid or underpaid creative labour.

Young creators also display media literacy: they can differentiate between content types, but they rarely receive formal support to understand advertising obligations or to navigate contract terms. The ASA warns that simply declaring an ambassador relationship in a bio does not meet disclosure standards; minors may not fully appreciate this nuance.

The economics of youth influencer programmes: unpaid labour, gifting and points systems

Ambassador programmes that reward participation with products, points or "early access" function as a form of labour exchange. Influencer marketing contracts that involve repeated tasks, scheduled participation at events, and sustained content production approximate work—and work is typically regulated when the worker is a minor.

Key economic elements:

Remuneration in-kind. Many brands compensate with products rather than cash. Legal advisers say points systems and gifted merchandise can still represent remuneration that would qualify as income under labour law.
Gamification. Brands use point-earning mechanics—complete tasks to get points, redeem points for goods—to encourage sustained participation. This can create ongoing obligations.
Event participation. Invites to live events often require travel, specific dress codes, and unpaid labour (handing out samples, filming on-brand content), with parents sometimes fronting costs and expecting reimbursement.
Platform incentives. Teen creators accept low-paid or unpaid gigs to build portfolios and follower reach, hoping for later opportunities.

Legal experts stress that the distinction between hobby and work matters. If a teenager’s activities are regular and structured, they may be legally classed as employment. That classification would trigger protections around hours, pay, and welfare—protections that do not uniformly apply to online creators at present.

Economic consequences for young creators include:

Short-term benefits: access to free products, social capital, event experiences.
Long-term risks: normalising unpaid labour and undervaluing creative labour offered by minors; potential missed school time; lack of savings or formal protections for earnings.
Unequal outcomes: micro-influencers may provide steady content for brands without clear pathways to professionalisation or fair compensation.

Why current child-protection laws fall short for online creators

Existing regulatory frameworks were not designed with social platforms and the rise of influencer economies in mind. Child performer laws typically assume centralised hiring, oversight by agents or studios, and a clear employment relationship. Social media, by contrast, decentralises content creation.

Gaps include:

Absence of specific protections for child creators. Many protections target child viewers or consumers, not creators who produce commercial content.
Parental consent as a default safeguard. Relying on parents to safeguard child creators places unequal burdens on families with different levels of understanding or capacity.
Lack of standardised “working hours” rules for online content creation. Child performance legislation limits working hours for on-set work but often does not apply to production filmed at home or in public by a creator.
Weak enforcement mechanisms. Detecting undisclosed commercial arrangements across thousands of platform posts is resource-intensive for regulators.

Legal scholars argue that protections should be functionally based: if a child’s activity meets criteria for work—regularity, remuneration, employer direction—then employment protections should apply regardless of medium. This approach removes the need to fit novel arrangements into old categories.

Cross-border contractual arrangements complicate this further. Brands operating in one jurisdiction may recruit minors in another under different rules. The result can be a “wild west” ecosystem where minimum protections depend on geography and platform policies rather than consistent statutory duties.

Brand responsibilities: what ethical practice looks like

Some brands already provide examples of stronger practice. Bubble emphasises clinical testing for younger users, requires parental consent, and restricts its ambassador programme to those aged 16 or older. Other brands offer vague promises of “engaging with young creators responsibly,” but stop short of publishing clear age thresholds, usage limits for actives, or duty-of-care frameworks.

A responsible brand approach should include:

Clear age policies: publish minimum ages for participation, verify ages where appropriate, and ensure consistent application of policies across markets.
Transparent contracts: present plain-language agreements for parents and guardians that set out tasks, hours, compensation, intellectual property rights and safety measures.
Medical safety protocols: avoid sending active ingredients such as retinols or strong acids to minors; provide clear product-use guidance and require clinical validation for products intended for young skin.
Disclosure training: ensure young creators understand advertising rules and provide tools or mandatory steps to disclose paid or gifted promotions.
Remuneration standards: offer cash or fair equivalent compensation for sustained or structured work, not only product gifts; record and report remuneration transparently.
Duty of care: assign a named brand representative responsible for safeguarding, provide parental contact lines, and limit on-site working hours for live events.
Data protection compliance: ensure compliance with laws like COPPA in the US for under-13s and GDPR-child protections in the EU, especially where programmes collect personal data.

Brands that embed these practices demonstrate respect for young creators’ wellbeing and reduce regulatory risk. They also gain consumer trust among parents and older audiences sensitive to exploitative practices.

Policy options and regulatory reform proposals

Policymakers are beginning to address influencer markets more broadly, but specific proposals for child creators remain underdeveloped. The following reforms would narrow current gaps:

Extend child performer protections to creators when activities meet employment-like criteria. That would include limits on hours, mandatory rest periods and requirements for welfare supervision at events.
Require age verification and parental declarations for ambassador programmes that target or accept minors, with audit trails for compliance.
Mandate transparent disclosure of promotional content, with platforms required to implement friction—e.g., mandatory ad labels in-app—for posts from accounts identified as child creators.
Create a “youth creator register” for structured programmes: a centralised, privacy-preserving registry that documents which young creators are engaged commercially and under what terms, enabling oversight without public exposure.
Strengthen clinical standards for products marketed to children, obligating safety data for younger cohorts and limiting distribution of certain actives to those with medical oversight.
Harmonise cross-border standards through cooperative agreements among major markets to prevent regulatory arbitrage.

Implementing such reforms requires balance. Overly prescriptive rules risk constraining positive forms of participation, creative self-expression and economic opportunity. Effective policy should protect without infantilising, focusing on consent, safety and fair compensation.

Practical steps for parents and young creators

Parents and teens can take concrete measures to protect interests and establish healthy boundaries.

For parents:

Read contracts carefully before signing. Look for clauses on tasks, hours, compensation, intellectual property and cancellation rights.
Ask for clear, written statements of compensation. Know whether the “payment” is product-based, points, or cash.
Seek limits on hours and event requirements. Ensure academic obligations are respected.
Insist on medical safety: request ingredient lists and refuse products with strong actives unless prescribed by a dermatologist.
Document communications and keep copies of parental consents.
Teach media literacy: explain disclosure rules, platform policies, and how to identify and report inappropriate behaviour.

For young creators:

Prioritise safety over short-term gains. Decline products you shouldn’t use and ask parents or a trusted adult for medical advice if unsure.
Label sponsored content clearly. Platforms and regulators will enforce disclosure requirements, and transparency builds audience trust.
Maintain boundaries between paid and personal content. Keep a separate cadence for promotional posts to avoid fatigue and exploitation.
Negotiate fair compensation when tasks are regular or time-consuming. Products are not equivalent to wages in many cases.
Keep records of hours and tasks performed; this can help in establishing whether activities should be classed as employment.

For parents and creators starting negotiations, sample questions to ask a brand:

What exact tasks are required, and how often?
What is the form and timing of compensation?
Who bears travel and wardrobe costs for events?
Are there safeguards for product safety and age-appropriate usage?
Who is the brand’s named duty-of-care contact?

These steps do not eliminate all risks, but they give families leverage to make informed decisions.

Real-world analogues: where regulation has adapted and where it lagged

Industries confronted by novel child participation issues provide useful analogues. Child acting and modeling moved from informal arrangements to regulated sectors long ago; lessons from that transition include the need for clear statutory definitions and routine oversight mechanisms.

Examples:

Child actors: Historic regulation defines work hours, mandates welfare and on-set educators, and often requires part of earnings be ring-fenced (e.g., the Coogan rule in California). That framework recognises the power imbalance between producers and minors.
Sports academies: Youth sports involve contractual relationships where governing bodies enforce limits on training intensity and competition exposure. These frameworks recognise development and safety risks.
Online gaming: Some jurisdictions have applied advertising and consumer protection standards to games targeting kids, such as limits on loot boxes and clearer labelling.

Unlike those domains, social-platform content creation often unfolds in private homes, impromptu public spaces, and across jurisdictions, which complicates oversight. Still, the core regulatory aim is consistent: where commercial activity involves minors, safeguards should be proportional to the risks.

How platforms can contribute: tools, enforcement and transparency

Platforms themselves hold significant responsibility and capability to reduce harms. Practical platform measures include:

Mandatory ad disclosure tooling that cannot be bypassed for accounts flagged as minors or for posts that use brand-supplied tracking codes.
Age-verification measures tied to ambassador programmes and gifting features, making it harder for brands to recruit underage creators without parental verification.
Reporting channels tailored to parents and guardians, with rapid escalation for potential exploitation.
Educational resources for creators and parents on advertising rules, safe product practices and data protection.
Audit logs for branded gifting to improve traceability of commercial relationships.

Platforms benefit from investing in safety: they reduce reputational risk, improve compliance with local law, and provide a safer environment that can sustain long-term user engagement.

Balancing agency and protection: ethical considerations

Young creators are not merely passive victims. They exercise agency, build skills, and sometimes derive real economic and social value from their content creation. Policy and industry responses must honour that agency rather than reflexively restrict participation. At the same time, agency does not eliminate the need for protection. Children are still developing cognitively and legally; they may lack full appreciation of long-term consequences related to privacy, contractual commitments, mental health and financial exploitation.

A balanced approach:

Preserve space for creative expression and skill development.
Require baseline protections that do not rely solely on parental capacity.
Ensure transparent and fair economic arrangements when content creation shifts from hobby to work.
Foster public education about media literacy for adolescents.

Following this approach recognises that many young creators will continue to participate in brand partnerships. The goal is to make that participation safe, informed and fairly rewarded.

What to watch next: signals for regulators, brands and consumers

Several developments will indicate whether the ecosystem is moving toward safer practices:

Enforcement decisions from the Italian AGCM and similar regulators elsewhere. A significant ruling against major groups would catalyse industry change.
Platform policy updates that specifically address minors’ participation in branded partnerships.
Industry-led guidelines or certification schemes for youth-influencer programmes that set minimum standards for age verification, compensation and clinical safety.
Litigation or regulatory clarification on whether certain influencer arrangements constitute employment for minors—a legal precedent would reshape how brands contract with youth.
Greater transparency from brands about ambassador demographics and compensation models.

Consumers and parents should follow these signals and hold brands accountable. Brands that pro-actively adopt stronger protections will gain competitive advantage in a more discerning market.

FAQ

Q: Are brands allowed to send skincare products to minors? A: Brands can send products to minors, but the legality and ethics depend on the jurisdiction, the product type, and how the relationship is structured. Safety concerns arise when brands send active ingredients such as retinols without clinical validation or appropriate supervision. Commercial relationships with minors also trigger questions about consent, compensation and duty of care.

Q: Do child performer laws protect social-media creators? A: Generally, child performer legislation applies to structured, employment-like roles such as acting and modeling. Many social-media activities fall outside those definitions, leaving creators without equivalent protections. If a creator’s activities meet employment criteria—regular hours, structured tasks, remuneration—then those laws may apply, but determinations are made case by case.

Q: What should parents look for before letting a child join an ambassador programme? A: Parents should review contracts carefully, demand transparency on tasks and compensation, verify who pays for travel and costs, check product ingredient lists for inappropriate actives, insist on limits to time commitments during school terms, and maintain a named brand contact for welfare concerns.

Q: Are points and free products considered payment? A: Yes. Legal advisers consider gifted products and points systems to be a form of remuneration. Where tasks are regular and structured, accepting non-cash compensation can still amount to being paid for work.

Q: What role should platforms play? A: Platforms should implement mandatory disclosure tools, age verification for branded gifting, easy reporting channels for parents, and educational resources for young creators. They also have a role in enforcing advertising rules and making commercial relationships transparent.

Q: Can minors legally promote anti-ageing or prescription-strength products? A: Promoting or using prescription-strength products typically requires medical oversight. Anti-ageing products are unnecessary for most minors, and certain actives can damage young skin. Brands should not send or encourage the use of prescription-strength or harsh actives to underage creators without appropriate clinical authority.

Q: What can brands do right now to act ethically? A: Brands should publish clear age policies, require parental consent with transparent contracts, avoid sending strong actives to minors, provide fair compensation for structured tasks, and appoint a duty-of-care contact. Clinical testing for products intended for younger users and advisory boards with pediatric dermatologists are recommended best practices.

Q: If a young creator is regularly producing promotional content, does that count as employment? A: It can. Legal tests focus on regularity, structure, and remuneration. Repeated tasks directed by a brand, production schedules and specified deliverables increase the likelihood that the arrangement will be deemed employment, triggering relevant protections.

Q: How can policymakers strengthen protections without curbing young people’s opportunities? A: Policy should target the functional characteristics of work—regularity, direction and remuneration—rather than platform-specific definitions. Reforms should require transparent contracts, fair compensation, age-appropriate clinical standards for products, and accessible dispute-resolution pathways, while preserving the ability of young people to create and express themselves online.

Q: Where can parents get more guidance? A: Parents should consult platform help centres for reporting tools and safety resources, seek legal advice for contract review if uncertain about terms, and consult pediatric dermatologists when products are intended for young skin. Industry codes and guidance from advertising regulators can offer insight into disclosure and commercial practice standards.

Q: What warning signs indicate a programme might be exploitative? A: Red flags include high time commitments with only product compensation, lack of written agreements, absence of parental supervision requirements, encouragement to use inappropriate products, onerous event obligations without reimbursement, and pressure to post without clear disclosure.

Q: What immediate steps can brands take to avoid regulatory scrutiny? A: Publish clear ambassador-age requirements, require parental consent, avoid sending actives to minors, include disclosure obligations in contracts, provide fair compensation for significant work, document safety testing for youth-targeted products, and cooperate with regulators when asked.

Q: Will these practices disappear? A: Unlikely. Brands will continue to leverage creators because of their reach and relevance. What should change is how these relationships are governed—moving from ad-hoc gifting and ambiguous contracts to regulated, transparent arrangements that respect the rights and wellbeing of young creators.

Q: What practical changes might follow the Italian AGCM’s investigations? A: Possible outcomes include mandated clearer labelling of products not intended for children, fines for covert marketing to minors, stricter oversight on ambassador programmes that target or recruit young creators, and wider industry scrutiny that prompts voluntary tightening of policies.

Q: Who should monitor implementation of reforms? A: A combination of advertising regulators, data-protection authorities, child welfare agencies and competition authorities should monitor compliance. Platforms and industry bodies should also publish compliance reports to enhance transparency.

Q: Is there a role for education? A: Yes. Media literacy and contract literacy should be part of broader youth education efforts. Teaching young people to identify advertising, understand contracts and appreciate the health implications of product use would reduce harm and empower safer participation.

This is a moment that tests how quickly laws and commercial practices adapt to new forms of youth labour and digital culture. Clearer rules, stronger clinical safeguards and better-informed parents and creators can keep the benefits—skill-building, expression and connection—while reducing the harms. Brands that lead with transparency and care will not only avoid regulatory pain; they will earn enduring trust from the communities they aim to reach.

Teen Influencers, Free Skincare and a Legal Grey Zone: How Brands Are Marketing Beauty to Children

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