PROTECTION OF CHILDREN AS CONSUMERS
III. RECENT DEVELOPMENTS IN THE AREA OF CHILDREN-CONSUMERS PROTECTION IN THE EU
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III. RECENT DEVELOPMENTS IN THE AREA OF CHILDREN-CONSUMERS
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(3) When general marketing content is addressed to children or is likely to be seen by them, the marketing purpose should be indicated in a manner that is appropriate and clear for children.
(4) Children are not to be targeted, urged or otherwise prompted to purchase app or in-game content, and in-games marketed for free should not require in-app or in-in-game purchases to play them in a satisfactory manner.
(5) Children should not be profiled for advertisement purposes.
One should note that these principles are not binding on national authorities, the European Commission or other competent entities in the area of consumer protection, and the power to decide on the legality of commercial practices remains solely with the competent authorities and courts. Therefore, their direct impact is limited to expressing the views of relevant organisations and institutions on the proper interpretation of applicable legislation in the area of children's consumerism. Even so, their significance should not be underestimated. Both the CPC Network and the European Commission play an essential role in the enforcement of EU consumer protection legislation and are granted considerable powers to take action against any breaches of the above mentioned regulations, meaning that their understanding of what constitutes fair advertising toward children is decisive in that regard. Moreover, the five principles have already been referred to in the recent case involving TikTok,[36] arguably the most popular social platform at the time of writing this contribution.[37]
In February 2021, the European Consumer Organisation (BEUC) filed a complaint under Article 27 of Regulation (EU) 2017/2394[38] with the European Commission and the CPC Network, accusing TikTok of unfair practices that constitute a widespread infringement of consumer rules with an EU dimension (Article 3 and Article 5 of Unfair Contract Terms Directive,[39] Article 5 and Article 7 of Unfair Commercial Practices Directive, Article 6 of Consumer Rights Directive, Article 6 of E-Commerce Directive 2000/31/EC,[40] etc.) and demanding a comprehensive investigation into TikTok's practices. Among other accusations, TikTok was accused of failing to protect children and teenagers from hidden advertising and potentially harmful content by encouraging participation in branded hashtag challenges where the users create content of specific products; allowing hidden advertising by influencers of fast food, sugary drinks, beauty products, clothing and video games without displaying the sponsored nature of such content; and failing to protect children from inappropriate content such as videos showing sexually-explicit or otherwise suggestive content.[41] Following an extensive discussion with the European Commission and the CPC Network, TikTok has committed to implementing several changes and aligning its practices with the EU legislation on advertising and consumer protection in order to avoid possible sanctions by the EU authorities. The main commitments include allowing users to report advertisements and offers that could potentially push or trick children into purchasing goods or services; requiring branded content to abide by a policy protecting users, which prohibits the promotion of inappropriate products and services (e.g. alcohol, "get rich quick" schemes and cigarettes);
reviewing videos of users with more than 10,000 followers to ensure that the content is appropriate; clarifying policies on how to purchase and use coins, how to get rewards and send
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gifts, including the option to withdraw within 14 days from the purchase; implementing new rules for hashtags and labels, etc. With the CPC Network undertaking to actively monitor the implementation of these commitments (including, for example, whether there is sufficient clarity around children's understanding of the commercial aspects of TikTok's practices, such as what concerns personalised advertising in light of the Five Key Principles of fair advertising to children), the European Commission, satisfied with the outcome, closed the investigation.[42] The seriousness with which TikTok approached the discussion and the willingness to change its practices to avoid sanctions demonstrate that the protection of consumers granted under the EU law is, indeed, effective. However, the BEUC (as well as national authorities for consumer protection)[43] have expressed genuine concerns over certain issues that remain unaddressed, such as the absence of a mechanism to protect young consumers from abuse by influencers when they purchase TikTok "virtual coins" and the lack of commitment to stop profiling and targeting children with personalised advertising.[44]
While the commitments made by TikTok and the fact that several institutions and organisations referred to the Five Key Principles in their communications and press releases are welcome progress in itself, further steps and ongoing monitoring might be needed to ensure their proper implementation in this and any future cases concerning children-consumers in the digital environment.
IV. LOOKING FORWARD
The EU laws and, consequently, national regulations implementing those laws cover a wide area of consumer protection, including consumer relationships formed in a digital environment and consumer transactions conducted online. However, the legislative work in the area of children-consumer protection is far from done. With technological advancements and the subsequent societal changes, new challenges keep appearing and demanding the attention of competent authorities. While the clarification of platforms as audiovisual media services has indeed eliminated doubts about whether the relevant EU legislation applies to such media and of the scope of protection to be granted to their users (which was of some concern in the Republic of Slovenia as well), some aspects remain highly problematic. In that regard, hidden or covert advertising in influencer marketing is especially worth highlighting. According to the Best Practice Recommendation on Influencer Marketing issued by the European Advertising Standards Alliance (EASA) in 2018, content provided by an influencer is defined as a marketing communication if the advertiser had editorial control over the message shared by the influencer (e.g. a final approval or general instructions) and if the advertiser compensated the influencer either by payment or other reciprocal arrangements (e.g. free products). In such cases, proper recognisability and disclosure of commercial communication should be guaranteed.[45] All notable social media platforms have adopted rules requiring influencers to disclose any compensation they received that could impact how viewers interpret their endorsement of a product or brand. Nevertheless, as demonstrated by the TikTok case, the enforcement of these rules is inconsistent, and the violations are difficult to detect unless reported (or even when reported).
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By no account is this a minor issue. According to a 2015 survey, only 1% of millennials trust advertisements, while 33% rely on blog reviews before making a purchase. 62% of them stated that if a brand engages with them on social networks, they are more likely to become a loyal customer.[46] Another survey of 2021 found that 70% of teens trust influencers more than traditional celebrities, 49% of consumers depend on influencer recommendations, and 40% had purchased something after seeing it on Twitter, YouTube or Instagram.[47] The influencer marketing industry is set to grow to approximately 16.4 billion U.S. dollars in 2022,[48] and the average earned media value per 1 U.S. dollar spent had increased to 5.78 dollars in 2020.[49] Despite these staggering numbers, only 14% of influencer posts (based on a sample of over 4200 Instagram posts analysed in 2020) fully comply with legal requirements and guidelines.[50] As the relationship between influencers and consumers is characterised by perceived closeness, authenticity and trust, influencer marketing exacerbates the vulnerabilities of children and consumers with low education or income more than other forms of media.[51]
The existing consumer protection legislation does not sufficiently address the issues arising from this type of advertising, even though it is regularly applied to influencer marketing by courts and other authorities.[52]
Some of the challenges arising from recent market trends have been tackled with the proposal of the Digital Services Act (proposed by the European Commission in December 2020), which sets new standards for the accountability of online platforms regarding illegal and harmful content. In April 2022, a political agreement was reached between the European Parliament and the EU Member States, clearing the path for its eventual adoption (subject to formal approval by the European Parliament and the Council). Once adopted, the Digital Services Act will be directly applicable across the EU. Inter alia, DSA contains measures to counter illegal goods, services or content online (e.g. a mechanism for users to easily flag such content and for platforms to cooperate with so-called 'trusted flaggers'), measures to empower users and civil society (e.g. the possibility to challenge platforms' content moderation decisions and seek redress, transparency measures for online platforms on a variety of issues, including on the algorithms used for recommending content or products to users), measures to assess and mitigate risks (e.g. new safeguards for the protection of minors and limits on the use of sensitive personal data for targeted advertising), enhanced supervision and enforcement by the Commission when it comes to very large online platforms, as well as the independent Digital Services Coordinators and Board for Digital Services.[53] In the context of children's consumerism, the Digital Services Act will oblige all online platforms to design their systems with consideration for the rights of child users, allowing them to easily understand the terms and conditions of the service they use. Furthermore, all online platforms offering services to children in the EU will be obliged to take appropriate and proportionate measures to ensure the privacy, safety and security of children on their services. All online platforms will be prohibited from presenting advertisements to children based on profiling, while very large online platforms and search engines will also have to consider any systemic risks concerning their services, including any actual or foreseeable negative effects in relation to the protection of children.[54] While the proposal does not explicitly refer to influencer marketing or other specific forms of content monetisation, Article 24 of the Digital Services Act integrates the most essential points made by the IMCO Committee in its draft report of May 2021 with respect
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to advertising business models undertaken by influencers.[55] While further steps are needed in the area of children-consumer protection both at the EU and national levels, and new issues related to the rapid technological and societal developments are expected to appear continuously, it is commendable that competent authorities are demonstrating notable political motivation to protect children and their increasingly significant role in consumer relationships.
[1] Total revenue of the global toy market from 2007 to 2020, https://www.statista.com/statistics/194395/revenue-of-the-global-toy-market-since-2007, accessed on 2 July 2022.
[2] Key figures for children and youth in 2021, https://www.alioze.com/en/figures-children-youth, accessed on 2 July 2022).
[3] For more on statistics of children-related spending and on pester power and its effects, see A. J. NICHOLLS and P. CULLEN, “The child–parent purchase relationship: ‘pester power’, human rights and retail ethic”, Journal of Retailing and Consumer Services No. 11, 2004, pp. 75–86. See also National Retail Federation, Fall 2019
Consumer View,
https://cdn.nrf.com/sites/default/files/2019-10/NRF%20Consumer%20View%20Fall%202019.pdf, accessed on 2 July 2022. For more on psychological and developmental aspects of children consumerism, see also P. M. VALKENBURG and J. CANTOR, “The development of a child into a consumer”, Applied Developmental Psychology No. 22, 2001, pp. 61-72; S. L.
CALVERT, “Children as Consumers: Advertising and Marketing”, The future of children Vol. 18, No. 1, 2008, pp. 205-234; D.R. JOHN, “Consumer Socialization of Children: A Retrospective Look at Twenty-Five Years of Research”, Journal of Consumer Research Vol. 26, No. 3, 1999, pp. 183–213; B. ŠRAMOVÁ, “Children’s Consumer Behavior”, in S. SABAH (ed.), Consumer Behavior - Practice Oriented Perspectives, London, IntechOpen, 2017.
[4] Spending on advertising to children worldwide from 2012 to 2021, https://www.statista.com/statistics/750865/kids-advertising-spending-worldwide, accessible on 2 July 2022.
[5] For more on marketing techniques see also S. L. CALVERT, “Children as Consumers: Advertising and Marketing”, The future of children Vol. 18, No. 1, 2008, pp. 205-234.
[6] S. L. CALVERT, “Children as Consumers: Advertising and Marketing”, The future of children Vol. 18, No.
1, 2008, pp. 205-234.
[7] For example, research from the American Psychological Association (APA) showed that children under the age of eight are unable to critically comprehend televised advertising messages and are prone to accept advertiser messages as truthful, accurate and unbiased. See Report of the APA Task Force on Advertising and Children of 20 February 2004, https://www.apa.org/pi/families/resources/advertising-children.pdf, accessed on 2 July 2022.
[8] Zakon o varstvu potrošnikov, Official Gazette of the Republic of Slovenia, No. 98/04 – official consolidated text, 114/06 – ZUE, 126/07, 86/09, 78/11, 38/14, 19/15, 55/17 – ZKolT and 31/18.
[9] For more, see the proposal for the Consumer Protection Act (ZVPot-1), https://e-uprava.gov.si/drzava-in-druzba/e-demokracija/predlogi-predpisov/predlog-predpisa.html?id=8592, accessed on 2 July 2022.
[10] Zakon o medijih, Official Gazette of the RS, No. 110/06 – official consolidated text, 36/08 – ZPOmK-1, 77/10 – ZSFCJA, 90/10 – odl. US, 87/11 – ZAvMS, 47/12, 47/15 – ZZSDT, 22/16, 39/16, 45/19 – odl. US, 67/19 – odl. US and 82/21.
[11] The mass media includes newspapers and magazines, radio and television channels, electronic publications, teletext, and other forms of edited programmes published daily or periodically through the transmission of written material, vocal material, sound or images in a manner accessible to the public (the first paragraph of Article 2 of ZMed).
[12] Zakon o avdiovizualnih medijskih storitvah, Official Gazette of the Republic of Slovenia, No. 87/11, 84/15 and 204/21.
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[13] Zakon o spremembah in dopolnitvah Zakona o avdiovizualnih medijskih storitvah, Official Gazette of the Republic of Slovenia, No. 204/21. See also justification accompanying the proposal of the amending act,
https://imss.dz-rs.si/IMiS/ImisAdmin.nsf/ImisnetAgent?OpenAgent&2&DZ-MSS-01/8fd173dd6d50a5b16b0e89f79633cf6b635d593a9c4c3e5379ceac1e94261e0b, accessed on 2 July 2022.
[14] Directive 2010/13/EU of the European Parliament and of the Council of 10 March 2010 on the coordination of certain provisions laid down by law, regulation or administrative action in Member States concerning the provision of audiovisual media services (Audiovisual Media Services Directive), OJ L 95, 15. 4. 2010, p. 1–24, consolidated version of 18 December 2018.
[15] The legislative process for the adoption of the amending act was lengthy and controversial, with the National Council of the Republic of Slovenia vetoing the first proposal. As a result, the Republic of Slovenia failed to comply with the deadline set in the Audiovisual Media Services Directive.
[16] See, for example, D. SCHITTON, “Vidiki varstva potrošnikov pri urejanju vplivnostnega marketinga v Sloveniji”, Pravna praksa Year 38, No. 12, 2019, pp. 13-15; D. SCHITTON, “Evropska direktiva o avdiovizualnih storitvah in podlage za ureditev vplivnostnega marketinga”, Pravna praksa Year 38, No. 9/10, 2019, pp. 22-24; D. SCHITTON, “Pravna vprašanja, povezana z vplivnostnim marketingom”, Pravna praksa Year 37, No. 12/13, 2018, pp. 15-17.
[17] Before ZAvMS-B, product placement was permitted in cinematographic works, films, docudramas, series and serials made for audiovisual media services, and sports and light entertainment programmes; in cases where there was no payment but only the provision of certain goods or services free of charge, such as production props and prizes, with a view to their inclusion in a programme; or if the value of the goods or services was negligible in proportion to the programme’s production costs (subject to some additional requirements).
[18] Slovenski oglaševalski kodeks, 4th edition, valid since 1 October 2008, https://www.soz.si/sites/default/files/soz_sok_slo.pdf, accessed on 2 July 2022.
[19] As the Slovenian Advertising Chamber is a full member of EASA (European Advertising Standards Alliance), the Codex provisions may be used in international dispute resolution procedures in EASA member states.
[20] The database of Advertising Tribunal decisions is available at https://www.soz.si/oglasevalsko_razsodisce/arhiv-razsodb, accessed on 2 July 2022.
[21] See Article 18 of the Codex.
[22] Decision of the Advertising Tribunal No. 263, 16 November 2015.
[23] Decision of the Advertising Tribunal No. 278, 16 June 2016.
[24] Decision of the Advertising Tribunal No. 343, 27 August 2019.
[25] Directive 2005/29/EC of the European Parliament and of the Council of 11 May 2005 concerning unfair business-to-consumer commercial practices in the internal market and amending Council Directive 84/450/EEC, Directives 97/7/EC, 98/27/EC and 2002/65/EC of the European Parliament and of the Council and Regulation (EC) No 2006/2004 of the European Parliament and of the Council (‘Unfair Commercial Practices Directive’), OJ L 149, 11. 6. 2005, pp. 22–39, consolidated version of 28 May 2022.
[26] Commercial practices are unfair if they are contrary to the requirements of professional diligence, and if they materially distort or are likely to materially distort the economic behaviour with regard to the product of the average consumer whom it reaches or to whom it is addressed, or of the average member of the group when a commercial practice is directed to a particular group of consumers (especially if they are misleading or aggressive). A commercial practice could be unfair if assessed based on a vulnerable consumer even if it is considered fair compared to the ‘average consumer’. See Article 5 of the Unfair Commercial Practices Directive and the following.
[27] Directive 2011/83/EU of the European Parliament and of the Council of 25 October 2011 on consumer rights, amending Council Directive 93/13/EEC and Directive 1999/44/EC of the European Parliament and of the Council and repealing Council Directive 85/577/EEC and Directive 97/7/EC of the European Parliament and of the Council, OJ L 304, 22. 11. 2011, pp. 64–88, consolidated version of 28 May 2022.
149 [28] See point 34 of the preamble of Consumer Rights Directive.
[29] Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation), OJ L 119, 4. 5. 2016, pp. 1–88.
[30] Point 38 of General Data Protection Regulation states that children merit specific protection with regard to their personal data, as they may be less aware of the risks, consequences and safeguards concerned and their rights in relation to the processing of personal data. Such specific protection should, in particular, apply to the use of personal data of children for the purposes of marketing or creating personality or user profiles and the collection of personal data with regard to children when using services offered directly to a child. The consent of the holder of parental responsibility should not be necessary in the context of preventive or counselling services offered directly to a child. See also Articles 6, 8 and 12 of the General Data Protection Regulation.
[31] As opposed to the average consumer who is considered to be able to make rational choices to find the best deals and benefit from competitive markets. For more on the concept of the average consumer in the European Court of Justice case law, see, for example Case C-210/96, Gut Springenheide GmbH and Rudolf Tusky v Oberkreisdirektor des Kreises Steinfurt - Amt für Lebensmittelüberwachung, 16 July 1998.
[32] European Parliament, Briefing on Vulnerable Customers, PE 690.619, May 2021,
<https://www.europarl.europa.eu/RegData/etudes/BRIE/2021/690619/EPRS_BRI(2021)690619_EN.pdf>
(accessed on 2 July 2022). See also L. WADDINGTON, “Vulnerable and confused: the protection of 'vulnerable' consumers under EU law”, European Law Review Vol. 38, No. 6, 2013, pp. 757-782 and E. KAPROU, “The current legal definition of vulnerable consumers in the UCPD: benefits and limitations of a focus on personal attributes”, in C. RIEFA and S. SAINTIER (eds.), Vulnerable consumers and the law: Consumer protection and access to justice, Routledge, 2020.
[33] European Commission, Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions: A digital decade for children and youth: the new European strategy for a better internet for kids (BIK+), COM/2022/212 final, Brussels, 11. 5. 2022, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=COM:2022:212:FIN, accessed on 2 July 2022.
[34] Five Key Principles of fair advertising to children,
<https://ec.europa.eu/info/sites/default/files/5_key_principles_9_june_2022.pdf> (accessed on 2 July 2022).
Compare with ICPEN Best Practice Principles: Marketing practices directed towards children online, June 2020,
https://icpen.org/sites/default/files/2020-06/ICPEN%20-%20Best%20Practice%20Principles%20for%20Marketing%20Practices%20Directed%20Towards%20Childre n%20Online%202020.pdf, accessed on 2 July 2022.
[35] The authors drafted the 5 key principles with a special consideration of situations in which children are particularly vulnerable, for example clicking on advertisement messages, visuals or banners embedded into or
‘hidden’ in online games, websites or mobile applications without understanding their commercial purpose, not understanding that some operators and providers of digital content and services derive revenues from the use of personal data, peer pressure to purchase additional coins, tokens and other in-game content that is useful or necessary to progress with a game, etc.
[36] TikTok qualifies as a video-sharing platform under Audiovisual Media Services Directive.
[37] The statistics collected in March 2022 shows that the total number of monthly active users in Q4 2021 was 1.2 billion, total number of TikTok downloads in 2021 was 656 million, TikTok generated an estimated 4.6 billion U.S. dollars revenue and consumer spending on TikTok in Q4 2021 amounted to 824.4 million U.S. dollars.
[38] Regulation (EU) 2017/2394 of the European Parliament and of the Council of 12 December 2017 on cooperation between national authorities responsible for the enforcement of consumer protection laws and repealing Regulation (EC) No 2006/2004, OJ L 345, 27. 12. 2017, pp. 1–26.
[39] Council Directive 93/13/EEC of 5 April 1993 on unfair terms in consumer contracts, OJ L 95, 21. 4. 1993, pp. 29–34, consolidated version of 28 May 2022.
[40] Directive 2000/31/EC of the European Parliament and of the Council of 8 June 2000 on certain legal aspects of information society services, in particular electronic commerce, in the Internal Market (Directive on electronic commerce), OJ L 178, 17. 7. 2000, pp. 1–16.
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[41] For more, see BEUC, TikTok complaint – letter to CPC and European Commission of 16 February 2021,
https://www.beuc.eu/publications/beuc-x-2021-013_beuc_submits_an_external_alert_to_the_cpc-network_about_tiktok_letter_to_ms_benassi.pdf, accessed on 2 July 2022, and BEUC, TikTok without Filters – a consumer law analysis of TikTok’s policies and practices – Report, <https://www.beuc.eu/publications/beuc-x-2021-012_tiktok_without_filters.pdf> (accessed on 2 July 2022). Additional complaints referred to infringements of data protection laws, unfair copyright terms, etc. See also J. AUSLOOS and V. VERDOODT, Confusing by Design: A Data Protection Law Analysis of TikTok's Privacy Policy, 2021,
https://www.beuc.eu/publications/beuc-x-2021-010_confusing_by_design-a_data_protection_law_analysis_of_tiktok_s_privacy_policy.pdf, accessed on 2 July 2022.
[42] European Commission, Press Release of 21 June 2022, EU Consumer protection: TikTok commits to align with EU rules to better protect consumers, https://ec.europa.eu/commission/presscorner/detail/en/ip_22_3823, accessed on 2 July 2022.
[43] See for example Slovenian Consumers' Association's press release of 22 June 2022, https://www.zps.si/mediji/izjave-za-javnost-2020/1127-izjave-za-javnost-2022/11436-zps-pomembni-pomisleki-ostajajo-nereseni-tudi-po-zakljucku-preiskave-tiktoka, accessed on 2 July 2022.
[44] BEUC press release of 21 June 2022, Investigation into TikTok closed with important questions unresolved - consumers left in the dark, <https://www.beuc.eu/publications/investigation-tiktok-closed-important-questions-unresolved-consumers-left-dark/html> (accessed on 2 July 2022).
[45] <https://www.arpp.org/wp-content/uploads/2021/02/EASA-BEST-PRACTICE-RECOMMENDATION-ON-INFLUENCER-MARKETING_2020_0.pdf> (accessed on 2 July 2022).
[46] D. SCHAWBEL, “10 New Findings About The Millennial Consumer”, Forbes, 20 January 2015,
<https://www.forbes.com/sites/danschawbel/2015/01/20/10-new-findings-about-the-millennial-consumer/?sh=4ab444b76c8f> (accessed on 2 July 2022).
[47] For more statistics, see 20 Surprising Influencer Marketing Statistics, 19 October 2021,
<https://digitalmarketinginstitute.com/blog/20-influencer-marketing-statistics-that-will-surprise-you> (accessed on 2 July 2022).
[48] The State of Influencer Marketing 2022: Benchmark Report,
<https://influencermarketinghub.com/influencer-marketing-benchmark-report/> (accessed on 2 July 2022).
[49] The State of Influencer Marketing 2020: Benchmark Report,
<https://influencermarketinghub.com/influencer-marketing-benchmark-report-2020, accessed on 2 July 2022.
[50] The State of Influencer Marketing 2020: Benchmark Report,
<https://influencermarketinghub.com/influencer-marketing-benchmark-report-2020, accessed on 2 July 2022.
[51] European Parliament, Study requested by the IMCO committee, The impact of influencers on advertising
and consumer protection in the Single Market, 2022,
<https://www.europarl.europa.eu/RegData/etudes/STUD/2022/703350/IPOL_STU(2022)703350_EN.pdf, accessed on 2 July 2022. See also M. DE VEIRMAN, L. HUDDERS and M. NELSON, Michelle, “What Is Influencer Marketing and How Does It Target Children? A Review and Direction for Future Research”, Frontiers in Psychology Vol. 10, 2019.
[52] For more criticism of the existing EU legislation, see also A. GARDE, “Advertising Regulation and the Protection of Children-Consumers in the European Union: In the Best Interests of … Commercial Operators?”, International Journal of Children’s Rights No. 19, 2011, pp. 149–171.
[53] Proposal for a Regulation of the European Parliament and of the Council on a Single Market For Digital Services (Digital Services Act) and amending Directive 2000/31/EC, Brussels, 15. 12. 2020, COM/2020/825 final,
<https://eur-lex.europa.eu/legal-content/en/TXT/?qid=1608117147218&uri=COM%3A2020%3A825%3AFIN>
(accessed on 2 July 2022). See also European Commission, Digital Services Act: Commission welcomes political agreement on rules ensuring a safe and accountable online environment, Press Release of 23 April 2022,
<https://ec.europa.eu/commission/presscorner/detail/en/IP_22_2545, accessed on 2 July 2022.
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[54] European Commission, Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions: A digital decade for children and youth: the new European strategy for a better internet for kids (BIK+), COM/2022/212 final, Brussels, 11. 5. 2022, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=COM:2022:212:FIN, accessed on 2 July 2022.
[55] European Parliament, Study requested by the IMCO committee, The impact of influencers on advertising
and consumer protection in the Single Market, 2022,
https://www.europarl.europa.eu/RegData/etudes/STUD/2022/703350/IPOL_STU(2022)703350_EN.pdf, accessed on 2 July 2022
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