‘An element of exploitation’: the world of TikTok child skincare influencers | TikTok

In a TikTok video, a young girl between the ages of 10 and 15 opens box after package of products she says were sent to her by skin care brands. He calls it a “PR shot.”

In another video, a 16-year-old young man opens the box of products he bought from a well-known brand. “I know young people are watching,” she says, before reading a note from the brand that reads, “I can’t wait for you to share your thoughts.”

It’s the booming world of kids’ skincare, where young online influencers as young as 13 accept freebies from brands and promote them to their followers. This comes despite warnings from dermatologists that children don’t need most skin care products and concerns from regulators that the practice exists in a legal gray area.

The Italian Competition Authority (AGCM) is investigating beauty brands Benefit and Sephora for adopting a “particularly insidious” strategy of using young influencers to market skincare to children.

AGCM launched an investigation into luxury goods company LVMH, which owns the brand, for allegedly trying to sell anti-aging treatments to children, possibly under 10 years old.

IT companies said They “may have failed to disclose” that the cosmetics they were selling were not aimed at children, “instead they appear to have encouraged their purchase through covert marketing strategies involving young micro-influencers.”

LVMH said Sephora and Benefit would “fully cooperate with the authorities” but declined to comment further. “All companies reaffirm that they strictly comply with the applicable Italian regulations,” the statement said.

An investigation by the Guardian revealed many videos of young people thanking brands for the products they bought. It has established ambassador programs open to children as young as 13, offering free products in exchange for online promotional content. However, the terms of these regulations lie in an unclear legal area.

For example, US skincare brand Evereden runs a program with no official age limit; it simply says it’s for “all ages and all stages” and promises early access to new products to those accepted. Some of the influencers the Guardian found linked to the brand were revealed to be as young as 12 years old.

Those under 18 must have parental permission to join. The brand says young “influencers” can get free monthly PR and event invitations. Ambassadors receive free products and have early access to new launches. In another Evereden video on TikTok, viewers are told that they can play games with the brand, answer questions and earn money. wasted on “beauties” It is sold in his own shop.

Evereden did not respond to attempts to contact him for comment. It did not clarify the age at which people could be accepted into the ambassador program.

On its website, when asked if it works with influencers under the age of 18, it says: “Yes! As a kids’ brand, we want to partner with our true audience, as well as their parents and guardians. We think it’s important for kids to see people like them taking care of their skin and feeling empowered with age-appropriate self-care routines. But we’re committed to engaging with young creators responsibly and ethically, and we require parent or guardian approval on all collaborations.”

Teen skincare brand Bubble is calling for ambassadors aged 16 and over for a similar program that previously accepted children as young as 13.

One girl the Guardian spoke to, who has several thousand followers, said she was recruited when she was under 16. “In September 2025, Bubble changed its policy regarding the program,” he said. “The reason I’m still part of the program is because I was an ambassador before the policy was implemented… so Bubble kept my family informed of the changes, but I’m still part of the program.”

Once accepted into Bubble’s ambassador program, participants are given a variety of tasks, from liking and sharing content to producing videos about products in exchange for points that can be used for purchases.

A spokesperson for Bubble said: “We do not partner or pay children to promote our products. Our ambassador program requires participants to be 16 or older and parental consent is required for anyone under 18.”

They added: “Clinical safety is fundamental to how we work. To our knowledge, we are one of the only brands to conduct clinical safety testing on consumers aged eight and over on products we recommend to younger users. If younger consumers are using skincare, there must be real clinical validation behind its safety. We also have a pediatric dermatologist as part of our strong dermatologists’ advisory board.”

The teenager said she’s seen online girls as young as 10 using retinol, which is really bad for your skin, especially if you’re under 25. He added that although he did not use such a strong product, a brand sent retinol and he had to explain to the company that he could not use it.

Experts say these programs exist in a regulatory gray area. Although the employment of child actors and models is governed by strict rules, including limits on working hours, these measures do not extend to child influencers.

Another young person interviewed by the Guardian, who has thousands of followers on TikTok and applied to represent a brand online, said: “I have always been interested in make-up and skin care.”

He said that for him, creating content is as much about self-expression as it is about promotion. She said talking about skin care helped her gain confidence and find her voice.

Her mother agreed, saying her daughter didn’t grow up with a lot of representation, adding: “Her online presence has become a space where she can be visible and confident in who she is.”

Her 16-year-old daughter had been invited to skin care brand events. “I usually pay for train tickets in advance and get a refund later, sometimes only partially,” he said. He recalled one event where attendees were instructed to wear black T-shirts and jeans. “We didn’t pack these, so I remember running around in the winter trying to find clothes.”

The 16-year-old’s duties at the events include distributing samples, answering participants’ questions and creating content for the TikTok page. He said: “I also did street interviews where I asked public questions about content posted on the brand’s social media.”

Since her daughter turned 16, they have become more selective in the jobs they accept. “As he starts his A-levels and considers university, he needs to realize that there may be an element of exploitation,” his mother said. He declined a recent invitation. “They just wanted him to stay there for three hours to hand out samples. He needs to devote that time to homework or revision.”

Lecturer in law at the University of Essex and co-ordinator of the Child Influencer Project, Dr. Francis Rees said legal lines were very blurred. “Many protections under advertising law focus on consumers, not the child creating the content,” he said.

Rees said unless criminal thresholds were exceeded, children appearing in online content were not afforded protection under the Online Safety Act or child performance legislation. “Brands and agencies have no obligation to care for the child in these situations,” he said. “They are contracting with the parent who is expected to protect the child.”

Christopher Gabbitas, a partner at Keystone Law, said that although British law provides greater protection for children in business and commercial activities, impressive regulations need to be evaluated on a case-by-case basis. “If a role involves regular and structured work, it may constitute employment regardless of whether payment is in cash,” he said. “Points, gifts or items still count as compensation.”

He added that cross-border schemes, including those governed by US law like Bubble, operate in the “wild west”.

The Advertising Standards Authority also requires influencer content to be clearly labeled as advertising and warns that simply declaring an ambassador affiliation in the bio is insufficient. This risks young people violating advertising rules without understanding their obligations.

The 16-year-old said he was paid £100 for a video but this was unusual and most other work was done in exchange for product rather than payment.

“Questions about unpaid youth labor are valid,” her mother said, but stressed it was important to reflect both the risks and benefits. “[My child’s] “His experience has also given him confidence, communication skills and a deeper understanding of how brands work.”

He added: “Through content creation, she learned to express her views, reflect her identity, and engage with diverse audiences: skills that go well beyond social media. Managing her platform also taught her organization, time management, and media literacy that many adults lack.”

Importantly, he said, parents’ involvement shapes how these lessons are absorbed. “By paying close attention, I helped him contextualize these experiences rather than accepting them uncritically.

“Taken together [my daughter’s] “Experience shows how complex young people’s digital lives are,” he added: “Unpaid or underpaid creative labor should not be normalized, but the skills and awareness it develops help explain why so many young people are engaged in these fields. “The challenge is not just protection, but also ensuring that young people’s work is recognized and fairly compensated.”