Toddlers on TikTok: When Skincare Routines Become Marketing — The Ethics, Law, and Risks Behind Using Very Young Children to Sell Products

Table of Contents

  1. Key Highlights:
  2. Introduction
  3. How TikTok became a stage for toddler skincare routines
  4. What the Guardian investigation revealed
  5. The ethics of using children who cannot consent
  6. Legal and regulatory landscape: Where rules apply and where gaps remain
  7. Why parents and brands take this path: incentives and murky economics
  8. Harms and risks: privacy, safety, health, and social development
  9. Precedents and comparable controversies
  10. How platforms, regulators, and industry should respond
  11. Practical guidance for parents, creators, and brands
  12. Balancing parental autonomy, creative freedom and child protection
  13. Monitoring and enforcement: Turning policy into practice
  14. What parents can do now: A checklist
  15. FAQ

Key Highlights:

  • A Guardian investigation identified roughly 400 TikTok videos featuring children under 13 giving skincare advice, including at least 90 clips with three-year-olds; many toddlers are subtitled because they cannot speak fully.
  • Concerns center on consent, undeclared commercial relationships, developmental harm from early exposure to marketing, and gaps in platform and regulatory safeguards.
  • A coordinated response from parents, brands, platforms, and regulators is needed: clearer disclosure rules, stronger age verification, and mandatory child-welfare safeguards for commercial content involving minors.

Introduction

A startling pattern has emerged on social media: toddlers who cannot yet speak clearly are positioned in front of cameras and presented as skincare experts. Short videos of children applying serums, recommending cleansers and praising particular brands have become common on TikTok, where the format rewards brief, emotion-driven clips. A recent investigation by the Guardian located roughly 400 such videos featuring children under 13 offering skincare advice. At least 90 of the children were as young as three; some were subtitled because their speech was not yet intelligible.

Those images — a toddler dabbing cream onto their cheeks while a parent films and an on-screen caption extols a product’s virtues — raise immediate questions. Are children being asked to participate, or simply positioned? Are parents disclosing payments or sponsorships? What harm might arise when marketing lands directly in the hands of very young children and the networks that follow them? This article breaks down the findings, examines the ethical and legal frameworks at play, and maps practical steps for families, platforms, brands, and policymakers.

How TikTok became a stage for toddler skincare routines

TikTok’s algorithm prizes short, emotionally resonant content that generates rapid engagement. The platform’s design amplifies content that holds attention and elicits reactions — laughter, surprise, delight or curiosity. Parents producing videos with their children often use familiar tropes: a child’s candid endorsement of a “miracle” cream, an animated routine set to catchy music, or a before-and-after montage. These formats translate to high view counts and strong audience response, which advertisers prize.

Creators who specialize in family content have long enjoyed large followings. Family vlogs, parenting tips, and kid-centric toy unboxings paved the way for a culture in which children are public-facing personalities. On TikTok, that culture intersects with beauty and skincare trends. Products pitched to teens and young adults — cleansers, sunscreens, gentle exfoliants, serums — are now being framed through the smiles and routines of toddlers. The immediate appeal is clear: young children are seen as authentic and adorable, an effective combination for persuasion. The broader implication is less discussed: children too young to form informed judgments are being enlisted to promote consumer behavior.

What the Guardian investigation revealed

Journalists reviewing thousands of TikTok posts identified approximately 400 videos where children under 13 offered skincare advice or endorsement. The investigation found several disturbing patterns:

  • Age and comprehension gaps: While some videos featured older children, researchers verified at least 90 clips that included three-year-olds. Several toddlers’ speech was so limited that parents or producers added subtitles to convey what the child “said.”
  • Explicit endorsements: Many videos presented statements framed as direct recommendations: “This is the only thing that worked for my skin,” or “We love X brand, try it.” Statements like these give the appearance of an intentional endorsement rather than casual, familial use.
  • Unclear commercial relationships: Few videos made transparent whether a financial transaction was involved. The line between unpaid family-sharing and sponsored promotion was often difficult to discern.
  • Peer influence and audience targeting: Short, child-fronted endorsements tend to perform well with young viewers and parents, increasing their value to brands seeking captive, influential audiences.

Guardian journalist Sarah Marsh described the findings as “harrowing,” highlighting the difficulty of assessing whether children are participating willingly. When toddlers are too young to form preferences or consent, the moral weight falls on adults who produce, edit, and disseminate the content.

The ethics of using children who cannot consent

Consent rests on comprehension. An individual must understand what they are agreeing to and the consequences that follow. Young children, especially toddlers, lack both the cognitive capacity and the social context to give informed consent to participate in commercial promotion. Ethical questions follow immediately.

Children appear in many forms of media — film, television, advertising — with long-standing protections such as performance contracts, supervision requirements, and financial safeguards. Social media has blurred those lines. The people who control a child’s online presence — typically parents or family members — are also often the content’s producers and beneficiaries. This dual role creates potential conflicts of interest.

Key ethical concerns include:

  • Exploitation: Using a child’s image to generate commercial value without adequate transparency or consideration of the child’s welfare can amount to exploitation.
  • Autonomy and future agency: A child’s online persona can shape future opportunities or liabilities. Content that remains publicly accessible may affect a child’s privacy, reputation, and future choices.
  • Normalizing commercial messages: Presenting marketing as a family routine teaches young audiences that commercial endorsement is a natural part of childhood behavior.
  • Emotional and psychological harm: Repeated exposure to performative behavior may condition children to seek approval through likes and views.

A responsible approach requires prioritizing a child’s welfare over short-term gain and recognizing that a child’s presence in content is not an automatic consent to commercial use of their image.

Legal and regulatory landscape: Where rules apply and where gaps remain

The legal frameworks around children, advertising and online platforms vary by jurisdiction but share common objectives: protect minors, ensure transparency in advertising, and regulate commercial exploitation. Several mechanisms are relevant to the issue of toddlers promoting skincare on TikTok.

Advertising disclosure rules

  • Advertising regulators in many countries require clear disclosure of paid promotions. In the United Kingdom, the Advertising Standards Authority (ASA) and the Committee of Advertising Practice (CAP) demand that consumers be able to identify advertising clearly. Influencer marketing guidance directs creators to use unambiguous disclosures when there is a commercial relationship. Similar requirements exist in the United States, where the Federal Trade Commission (FTC) enforces that endorsements must be truthful and that material connections between advertisers and endorsers must be disclosed.
  • Enforcement remains uneven. Influencer content often appears informal and personal, complicating detection and policing. When the person endorsing a product is a child, identification of commercial intent becomes more opaque.

Children’s online privacy rules

  • In the U.S., the Children’s Online Privacy Protection Act (COPPA) restricts operators of online services from collecting personal information from children under 13 without parental consent. Platforms that host content generated by or aimed at children must display age-appropriate privacy protections and parental controls.
  • In jurisdictions outside the U.S., similar privacy protections exist in law or regulation, though standards and enforcement practices vary.

Platform rules and age limits

  • Most major social platforms set a minimum user age of 13. In practice, younger children often appear in videos uploaded by adults. Platforms typically ban users under the minimum age from creating accounts, but enforcement of age limits is imperfect.
  • Platforms also have specific policies on advertising, branded content, and child safety. For content that includes minors, platforms sometimes require parental consent or set additional safeguards, but policies differ and are inconsistently enforced.

Recent legislative developments

  • The UK's Online Safety Act requires online services to take steps to protect children from harmful content and sets duties of care for platforms. The law encourages stronger moderation and requires certain services to assess and mitigate risks to children’s safety.
  • Lawmakers globally are increasing scrutiny of social media’s impact on children, with hearings, proposed bills, and regulator inquiries drawing attention to the commercial use of minors online.

Legal frameworks provide tools to curb exploitative practices, but gaps remain in detection, cross-border enforcement, and the fine-grained regulation of content involving very young children. Many influencers and family creators operate in a grey zone where the distinction between personal sharing and advertising is blurred.

Why parents and brands take this path: incentives and murky economics

There are multiple reasons parents put young children on camera and why brands tolerate or encourage such content.

Financial incentives

  • Sponsorships, affiliate links, product-gift arrangements and advertising revenue can generate income. For some families, content creation is a primary or supplementary income source.
  • Brands benefit from authentic-appearing endorsements. A toddler’s “recommendation” often performs well precisely because it appears unscripted and sincere.

Social incentives

  • Likes, shares, and follower counts fulfill social validation needs. Posting family content can be a way to connect with other parents, boost social standing, or chronicle family life.
  • Some parents view sharing as an online scrapbook, not recognizing the commercial value their child’s content may accrue.

Marketing value for brands

  • Children influence household purchasing decisions and sway peers. Brands targeting families want to reach both parent consumers and younger viewers.
  • User-generated content that includes children helps brands appear relatable and trustworthy.

Blurry disclosure norms

  • Many creators do not use formal contracts or fail to understand the disclosure requirements governing sponsored content. Even when brands pay or provide free products, public declarations of commercial relationships can be missing.
  • The casual tone of TikTok makes paid promotions feel like private endorsements, reducing the perceived need for disclosure.

The result is a patchwork ecosystem where commercial and personal motives mingle, obscuring whether a child’s appearance serves a family’s expression or a brand’s marketing strategy.

Harms and risks: privacy, safety, health, and social development

The use of toddlers to market skincare products entails several categories of potential harm.

Privacy and digital footprint

  • Content posted online is often persistent. A toddler’s image and personal details can remain accessible indefinitely, creating a digital footprint they did not consent to.
  • Personal data collected by platforms about a child or the viewers of content may be used for targeted advertising, raising COPPA-related concerns and broader privacy questions.

Physical safety and product risks

  • Skincare products are not always formulated or tested for very young skin. Promoting adult or general-market products for toddler use risks encouraging inappropriate application.
  • Encouraging children to handle or apply products without proper supervision could lead to misuse, allergic reactions, or accidental ingestion.

Psychological and developmental effects

  • Early and repeated exposure to performative routines can shape a child’s sense of self and priorities. Children raised in front of a camera may internalize the expectation of public performance.
  • Advertising directed at children influences norms about appearance, grooming and consumerism. When marketing presents skincare as a routine for toddlers, it normalizes a product-focused conception of personal care from a very young age.

Peer influence and social contagion

  • Children are highly susceptible to peer cues. When popular videos show toddlers endorsing a product, other children may emulate the behavior or pester parents for purchases.
  • This dynamic accelerates the spread of product trends among younger audiences, shifting consumption patterns earlier in childhood.

Economic exploitation and lack of safeguards

  • Without transparent contracts or protections, children may not receive fair compensation for commercial exploitation of their image.
  • In traditional media industries, child performers work under labor protections and trust arrangements. Social media often lacks comparable structures, allowing parents to monetize children’s appearances without formal safeguards.

The cumulative effect of these harms is both immediate and deferred: a child’s short-term exposure to a product promotion can entrench long-term digital identity and consumer behaviors.

Precedents and comparable controversies

Social media’s commodification of childhood is not new. Several high-profile cases provide context.

Family vlogging controversies

  • Channels that chronicle domestic life have sometimes crossed into abusive territory, staging pranks or disciplinary content that drew heavy criticism and regulatory attention. Instances in the past raised questions about consent, exploitation, and child welfare.
  • Such controversies prompted debates about whether parents should be permitted to broadcast their children’s lives without independent oversight.

Child influencer success stories and concerns

  • Channels featuring children can become extremely lucrative. The rise of toy-review and kid-focused channels produced young stars with lucrative brand deals. Behind many of those successes are concerns about who controls earnings, how children’s time is managed, and whether long-term welfare was prioritized.
  • Some families established legal and financial protections after industry scrutiny; others did not.

Past regulatory responses

  • Regulatory bodies have occasionally acted: advertising regulators have issued rulings against undisclosed influencer ads, and child welfare agencies have investigated family content that posed risks.
  • Those responses show that oversight is possible but require intervention, resources and cross-agency collaboration.

These precedents demonstrate both the patterns that lead to harm and the possible remedies when attention and enforcement are applied.

How platforms, regulators, and industry should respond

Fixing this problem requires coordinated action across multiple actors. Steps that can be taken include:

Stricter age verification and content labeling

  • Platforms should implement stronger age-verification processes at account creation and for children prominently featured in content. While no system is foolproof, enhanced checks increase the difficulty of normalizing child participation.
  • Content that prominently features minors, especially very young children, should carry a clear label indicating whether there is any commercial relationship, and whether the child’s appearance is sponsored.

Mandatory disclosure and enforcement

  • Regulators should enforce influencer disclosure rules rigorously and prioritize cases involving minors. Penalties for failing to disclose sponsored content must be meaningful and enforced consistently.
  • Brands should be required to maintain records of sponsored content involving children and to ensure compensation and welfare protections are in place.

Child-welfare safeguards for commercial content

  • Platforms must adopt policies that require creators to confirm a minor’s participation is age-appropriate, safe, and accompanied by transparency about commercial ties.
  • Policies could mandate that content featuring children under a defined age must undergo human review before monetization or inclusion in recommendation systems.

Financial protections and trust arrangements

  • When commercial income arises from a child’s image or performance, legal structures should require a portion to be set aside in a protected trust for the child’s benefit, mirroring long-established protections in entertainment industries.

Education and clear guidance for parents and creators

  • Regulators and platforms should publish plain-language guidance for parents explaining legal duties, potential harms, and best practices for safeguarding children online.
  • Brand guidelines should discourage marketing practices that use toddlers as endorsers and encourage partnerships that prioritize child welfare.

Algorithmic and product design changes

  • Recommendation systems should deprioritize content that exploits minors for commercial gain, particularly when a child’s participation is questionable.
  • Platforms can promote alternatives: content that features parenting advice without using a child as the focal point for product promotion, or that uses explicit editorial review.

These measures, applied together, would raise the cost and visibility of exploitative practices, protect children’s rights, and preserve legitimate family expression.

Practical guidance for parents, creators, and brands

Parents, creators and brands face choices today. The following steps balance freedom of expression with child welfare.

For parents and creators

  • Prioritize the child’s welfare. Ask whether the child can meaningfully consent and whether participation serves the child’s interests.
  • Use clear disclosure. If a video contains a paid promotion, label it explicitly and accurately with terms viewers will understand (e.g., “sponsored” or “paid partnership”).
  • Limit personal data. Avoid sharing identifying details such as full names, addresses, or school information. Adjust privacy settings to restrict downloads and limit public access.
  • Consider long-term ramifications. Think about how a child’s online image might be perceived in adolescence or adulthood.
  • Protect earnings. If the content generates funds attributable to the child’s image, arrange for a portion to be saved in a trust or an equivalent protected account for the child’s future use.
  • Avoid normalizing adult-only products. Consult pediatric guidance before applying skincare products to young children; many formulations are unnecessary or potentially irritating for toddlers’ sensitive skin.

For brands and marketers

  • Avoid deliberately targeting very young children with beauty or skincare products. When working with family creators, choose partners who follow clear child-safety protocols and transparent disclosure practices.
  • Require written consent and documented disclosure. Contracts should specify how sponsorships will be labeled and how the child’s welfare will be protected on set and during production.
  • Adopt a conservative approach. If the child is very young or cannot coherently describe the product, do not use them as a paid endorser.

For platforms

  • Enforce existing advertising disclosure requirements and make it easier for viewers to flag suspected undisclosed promotions involving minors.
  • Provide creators with tools and prompts to disclose paid content clearly at upload time.
  • Implement human review thresholds for monetization when videos prominently feature children under a certain age.

These actions reduce ambiguity and place children’s rights at the center of decision-making.

Balancing parental autonomy, creative freedom and child protection

Many parents view content-sharing as an expression of family life and an extension of parenting in the digital era. Some families derive income from content creation, and children’s participation can be benign or beneficial when handled responsibly. The challenge lies in safeguarding children’s rights while preserving legitimate forms of expression and enterprise.

A balanced approach recognizes three truths:

  • Parents have a wide range of motives for sharing: memory-making, community-building, and livelihood. Not all family content is exploitative.
  • Commercialization of a child’s presence must be transparent and regulated to prevent harm.
  • Legal and technological systems must adapt to ensure that modern media’s affordances do not become a vector for exploitation.

Policies and norms should steer towards incremental but enforceable protections, rather than blanket prohibitions that could deny families beneficial opportunities.

Monitoring and enforcement: Turning policy into practice

Law and guidance are only as strong as their enforcement. Effective monitoring requires resources, data-sharing arrangements and cross-border cooperation.

Regulatory agencies should:

  • Prioritize investigations of content involving very young children and alleged undisclosed commercial relationships.
  • Coordinate with platforms to request records and advertising documentation where commercial intent is suspected.
  • Publicize rulings and penalties to create deterrence and set clear expectations.

Platforms should:

  • Provide regulators with access to data when lawful and necessary.
  • Train moderation teams on the indicators of undisclosed sponsored content, especially in family and child-focused verticals.
  • Share transparency reports detailing actions taken on content that exploits minors.

Civil society and journalists will continue to play a watchdog role, surfacing problematic practices and prompting official action. The Guardian’s investigation is an example of how media scrutiny can catalyze public debate and regulatory attention.

What parents can do now: A checklist

If you are a parent who posts content or considers doing so, use this checklist:

  • Assess capacity: Is your child old enough to understand participation? If not, avoid using them as an endorser.
  • Think long-term: Will you be comfortable with this content existing when your child is older?
  • Be transparent: Label any commercial relationship plainly.
  • Limit data: Don’t disclose precise location or personal identifiers.
  • Prioritize safety: Never encourage a child to use products not recommended for their age; consult a pediatrician before applying cosmetic products to toddlers.
  • Protect earnings: Establish financial safeguards for any income attributed to the child.
  • Seek advice: Consult child welfare experts or legal counsel when in doubt.

Following these steps reduces immediate and future risks to your child while preserving your ability to share family moments responsibly.

FAQ

Q: Is it legal for parents to post videos of their toddlers endorsing products? A: Posting family videos is generally legal when parents are the account holders and upload their child’s image. However, when a commercial relationship exists — payment, free products in exchange for a promotion, affiliate links, etc. — disclosure and advertising rules may apply. Regulators require that viewers be able to identify sponsored content. Additionally, privacy and child protection laws may impose obligations depending on jurisdiction. Legal frameworks vary across countries, and enforcement is inconsistent.

Q: Are brands breaking the law by using toddlers in marketing? A: Brands that pay for endorsements and fail to ensure clear disclosure may run afoul of advertising rules and risk regulatory action. Even absent explicit payment, practices that target children with commercial messaging or that exploit child performers without appropriate safeguards may attract scrutiny from consumer protection and child welfare agencies. Brands should apply conservative standards when minors are involved.

Q: How can I tell if a video featuring a child is a paid advertisement? A: Look for explicit labels such as “#ad,” “sponsored,” “paid partnership,” or platform-native disclosure tags. Many creators may not follow rules, so the absence of a label does not guarantee absence of a commercial relationship. If a video mentions a brand in a promotional tone, includes links to purchase, or features a coupon code, those are indicators of a commercial arrangement.

Q: What are the developmental risks of toddlers participating in such content? A: Toddlers lack the cognitive capacity to consent to commercial use of their image and may be unable to understand the social consequences of public exposure. Repeated performative behavior can shape identity, normalize consumerism, and affect privacy expectations. Additionally, promoting skincare products without medical guidance can expose children to products inappropriate for their skin.

Q: What should a parent do if they are concerned about a child’s online presence created by someone else? A: If the child’s welfare is at risk, contact local child protection services. If the issue is undisclosed commercial use or privacy concerns, report the content to the platform and to relevant advertising regulators. Document the content and any suspicious indications of payment or brand relationships. Seek legal advice when formal action may be warranted.

Q: Should platforms ban children under a certain age from being featured in monetized content? A: A blanket ban would be difficult to implement fairly and might restrict legitimate family expression. However, platforms should require stricter safeguards, disclosures, and human review when very young children are featured in content that is monetized or highly commercial. A hybrid approach — increased protections rather than outright bans — is more practicable and sensitive to families who share moments without commercial intent.

Q: What steps can regulators take to reduce harm? A: Regulators can clarify rules around disclosures involving minors, prioritize enforcement against non-compliant creators and brands, require financial protections for children whose images generate revenue, and mandate transparency reporting from platforms. Cooperation across jurisdictions is crucial given the global reach of social media.

Q: Are there pediatric or dermatological concerns with applying skincare products to toddlers? A: Many common skincare products are formulated for adult skin and may contain active ingredients that irritate sensitive, developing skin. Parents should consult pediatricians or dermatologists before using new products on toddlers. Sunscreen recommended by pediatric guidelines is often appropriate, but other cosmetic routines that include acids, retinoids or adult-strength exfoliants are unsafe for young children.

Q: How can brands be held accountable? A: Brands can be held accountable through regulatory investigations into undisclosed endorsements, public pressure from users and media, and loss of reputation. Advertisers should adopt strict vetting processes for influencers, require documented disclosures, and refuse to pay for endorsements that involve very young children without robust child-welfare safeguards.

Q: If my child is already featured in monetized content, what protective steps should I take? A: Review contracts and sponsorship terms carefully. Seek legal counsel to ensure that earnings are preserved for the child, ideally in a legally protected trust or account. Evaluate the content’s privacy settings and consider limiting public access. Consider removing particularly sensitive content or re-editing to protect the child’s identity. Prioritize the child’s mental and emotional needs over revenue.

The Guardian’s investigation underscores a broader tension: social media’s capacity to amplify family life collides with the commercial incentives of modern marketing. Toddlers cannot consent to become spokespeople for products. That simple fact compels action. Parents, platforms, brands and regulators must adopt clearer norms and enforceable rules that protect children while allowing families to share responsibly. The remedy is not silence; it is safeguards — transparently enforced, consistently applied, and designed with children’s long-term welfare in mind.