YouTube Following its marketplace monitoring of children’s advertising, BBB National Programs’ Children’s Advertising Review Unit (CARU) recommended that MrBeastYouTube, LLC, and its affiliate Feastables, update their advertising and data collection practices for the MrBeast YouTube channel, Feastables’ Sweepstakes, and the Feastables website to comply with CARU’s Advertising Guidelines, CARU’s Privacy Guidelines, and the Children’s Online Privacy Protection Act (COPPA).
MrBeast, the online persona of Jimmy Donaldson, is one of the world’s most popular content creators on the YouTube platform, with a large fan base of children and young adults. The MrBeast YouTube channel has over 400 million subscribers. In 2022, MrBeast launched Feastables, a chocolate brand that generated over $…
YouTube Following its marketplace monitoring of children’s advertising, BBB National Programs’ Children’s Advertising Review Unit (CARU) recommended that MrBeastYouTube, LLC, and its affiliate Feastables, update their advertising and data collection practices for the MrBeast YouTube channel, Feastables’ Sweepstakes, and the Feastables website to comply with CARU’s Advertising Guidelines, CARU’s Privacy Guidelines, and the Children’s Online Privacy Protection Act (COPPA).
MrBeast, the online persona of Jimmy Donaldson, is one of the world’s most popular content creators on the YouTube platform, with a large fan base of children and young adults. The MrBeast YouTube channel has over 400 million subscribers. In 2022, MrBeast launched Feastables, a chocolate brand that generated over $215 million in revenue in 2024.
CARU’s inquiry focused on whether certain advertising on the MrBeast YouTube channel was identifiable as advertising; whether certain claims for Feastables chocolate bars were misleading; whether promotions for Feastables sweepstakes clearly disclosed free means of entry, odds of winning, and minimum age requirements; and whether personally identifiable information was collected from children prior to obtaining verifiable parental consent (VPC).
MrBeast YouTube Advertising
CARU observed several MrBeast YouTube videos where the video descriptions and pinned comments contained advertising content unrelated to the videos. This content was not clearly labeled or otherwise identifiable as advertising to children in the audience.
Because it would not be clear to children that the video descriptions and pinned comments were advertising messages, CARU determined that MrBeast’s YouTube channel did not comply with CARU’s Ad Guidelines’ provision that advertising should be presented in a way that makes clear to the child audience that it is advertising.
CARU accordingly recommended that the channel update its advertising practices to ensure that all advertisements are identifiable as ads to children.
Feastables Advertising
In a promotional video later removed from his YouTube channel, MrBeast posted a “Massive Announcement!” where MrBeast debuted the new Feastables chocolate bars and purported to conduct a blind taste test between the new Feastables chocolate bars and “top European chocolates” that showed all tasters preferring the Feastables bar.
Although MrBeast contended the taste test demonstration was not intended to be taken seriously, CARU concluded that it would appear to be a valid taste test to children.
CARU determined Feastables violated CARU’s Ad Guidelines by misrepresenting that the taste test was a valid demonstration that consumers prefer Feastables chocolate bars’ taste compared to similar chocolates.
CARU recommended that Feastables ensure ad claims are truthful and not misleading to children.
Feastables Sweepstakes
At the end of the “Massive Announcement” Feastables video, MrBeast announced the “Blue Wave $10K sweepstakes” saying, “…for 30 days straight, we are giving away $10,000 to a lucky customer who scans the QR code on the back of any new Feastables bar…You might win 10 grand…” and to “Upload Your Receipt & Enter to Win. Confirm your purchase below to enter for a chance to win 10k + a year’s supply of our new chocolate. MORE BARS = MORE ENTRIES.”
Contrary to CARU’s Ad Guidelines’ provision that sweepstakes promotions must clearly and conspicuously disclose a free means of entry, the free means of entering the sweepstakes was only disclosed in the FAQ section linked to halfway down the page. The FAQ also stated that the minimum age of participation is 16.
Based on the overall net impression of the ads for the Blue Wave sweepstakes, CARU determined that the free method of entry was not adequately disclosed. CARU determined that a child may have the reasonable takeaway that they must purchase Feastables chocolate bars to enter the sweepstakes. A second reasonable takeaway is that a child should purchase as many as 10 chocolate bars every day and scan the QR codes to maximize their chances of winning.
In MrBeast’s 2024 Halloween sweepstakes, Feastables encouraged participants to submit up to 24 entries daily until October 30 for a chance to win $10,000, with a grand prize of $1,000,000 on Halloween Day. The ad copy stated, “$10,000 USD Daily Winner. Enter with Purchase Through October 30.” In very small print was the disclaimer, “No purchase necessary, Click below for details.” The official rules stated that participants must be at least 13 years old with parental permission and entrants under 13 are not allowed.
CARU noted the sweepstakes did not include an age gate to ensure that participants were at least 13 years old, nor did the sweepstakes provide a method, at any point in the sweepstakes entry flow, where participants could enter their parent or guardian’s information to obtain VPC. The entry form required a participant to enter personal information including full name, phone number, address, and email address. To upload the receipt photo, the prompt, “I affirm that I have read, understand and agree to the Official Rules,” was pre-checked.
Additionally, the advertisement featured a large countdown timer with the text “Time is Running Out. Buy Feastables for a chance to win $10K,” which CARU determined constituted sales pressure.
Sweepstakes Advertising Issues
CARU determined that the Feastables Blue Wave $10K and Halloween $10K sweepstakes did not comply with CARU’s Ad Guidelines by failing to clearly and conspicuously disclose the free means of entry, the minimum age requirements, and the likelihood of winning, and by promoting the overconsumption of chocolate bars.
CARU recommended ensuring that material information is disclosed clearly and conspicuously to children in language they can understand, that advertising is clearly identifiable as advertising to the children, and that advertising is truthful, not misleading, and appropriate to the child audience.
Sweepstakes Privacy Issues
CARU’s Privacy Guidelines and COPPA require websites directed to children, including mixed audience sites, to obtain VPC before collecting, using, or disclosing personal information from children under 13. Pursuant to COPPA, mixed audience sites may implement a neutral age-screening mechanism to ensure the site does not collect personally identifiable information from children under 13 without first obtaining VPC.
CARU determined that the Feastables website was a mixed audience site that appealed to children under the age of 13 as a secondary audience and, therefore, Feastables had a reasonable expectation that children under 13 would visit the website.
Therefore, CARU determined that the Feastables Blue Wave $10K and Halloween $10K sweepstakes did not comply with CARU’s Privacy Guidelines and potentially COPPA by failing to provide a neutral age-screening mechanism to ensure the sweepstakes website did not collect personally identifiable information from children under the age of 13 without first obtaining VPC.
Other Feastables Website Privacy Issues
In its review of the Feastables website, CARU observed a full-page popup that repeatedly solicited the user’s email address with a call to action stating, “MrBeast Wants You to Join the Crew.” When CARU provided an email address through this popup, it discovered that a second popup would generate, soliciting the user’s phone number this time. When testing the network traffic of the site during this interaction, CARU saw evidence that the email and phone contact information was sent to non-affiliate third parties.
In light of Feastables’ future plans to solely run sweepstakes for ages 18 and up, CARU further recommended that Feastables consider whether a neutral and effective age gate would be appropriate for future sweepstakes and promotions.
Since the opening of the inquiry, CARU has worked with the MrBeast team, which has cooperated to implement CARU’s recommendations regarding CARU’s Advertising Guidelines, CARU’s Privacy Guidelines, and COPPA.
In the advertiser statement, MrBeast and Feastables stated that it “appreciates CARU’s mission to promote responsible children’s advertising. However, they do not agree with all the conclusions made in the decision or the premises on which they were based. Furthermore, a variety of the issues raised by CARU relate to practices long since revised and/or discontinued. Notwithstanding, MrBeast and Feastables certainly will take CARU’s concerns under advisement as it develops future advertisements which appear in children’s media.”
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