What you may not say to a child
In the UK, the CAP Code's children's section (for under-16s) bans direct exhortation: an ad must not tell children to buy a product or to ask a parent to buy it for them. It must not make children feel inferior or left out for not having it, exploit their credulity, or show them behaving unsafely. In the US, CARU's guidelines for advertising to children under 13, revised in 2021, cover the same ground and now address influencers, apps and in-game purchases. Generated copy naturally drifts into calls to action like 'get yours now' or 'ask for it this Christmas'. In children's work those phrases need to be banned words, not review comments.
Real size, real function
A basic rule of toy advertising is that the toy must be shown as it is. Children judge size against the hands and bodies around it, so a generated child holding an oversized figure misleads. The toy must do only what it really does: a drone that cannot hold a hover should not hover, a doll should not move on its own, and fantasy sequences must be clearly separate from the product demonstration. Say what is in the box. CARU expects ads to make clear what comes with the purchase and to disclose anything essential that is sold separately, such as batteries. Scene generation invents helpfully; in this category every invented capability is a potential complaint.
Safety warnings and safe scenes
Safety runs through both the product and the picture. In the US, toys with small parts, small balls, marbles or latex balloons need choking-hazard warnings on the packaging, and under the Federal Hazardous Substances Act and 16 CFR 1500.20 the same warnings must appear in catalogues and on websites that let people buy the product. In the EU, warnings that affect the decision to buy, such as 'not suitable for children under 36 months', must be visible before purchase, including online. The generated scene matters as much: no small parts near a toddler's mouth, no child unsupervised near water or on a high surface, helmets on scooters and bikes, age-appropriate toys in the right hands. Brief these as rules, because image models will not infer them.
Children's data, likeness and generated children
Campaigns that invite children to upload a photo, a drawing with their name or a voice recording collect personal information. Under the US COPPA Rule (16 CFR Part 312), photos, video and audio containing a child's image or voice count as personal information, and collecting them from under-13s needs verifiable parental consent; the rule's 2025 amendments apply in full from April 2026. The EU's Digital Services Act bars online platforms from showing minors ads based on profiling. Generated children can replace child models on some shoots, which avoids child performance licences and long set days, but never base one on a real child without a parent's written consent. The studio's brand hub can hold banned words and claims for children's work, with every asset approved before release.
Updated 25 September 2026 · General information, not legal advice. Rules change, so check the current text with your legal team before relying on it.