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Control

A toy for children includes a companion chatbot

A physical product designed, marketed or manufactured for play by children does not include an AI chatbot that gives adaptive, human-like responses, can meet a user's social needs and sustains a relationship across interactions (a companion chatbot) where the law prohibits it.

Informational data, not legal advice. Summaries and rules have not been reviewed by a lawyer: always verify official law text for decisions. A suggested guard is intended to address each rule; adding it is not a statement of compliance to that law.

Control id cond.companion-chatbot-in-childrens-toy

Reach

1items this one guard addresses
0jurisdictions where binding law on it is in force
1more where it is enacted, not yet applying
0standards and frameworks on the same control

enacted, not yet applying in California (US-CA); next date 2027-01-01.

Trust and provenance

How far the rules this guard addresses have been checked. Each rule links to its provision, with its citation, official text and its own panel.

This control
Audit-grade: meets all 3 checks of the TwinEthos audit standard that apply to it.
Lanes
Binding law — not yet in force or stayed 1
Verification
Sources last verified 4 Oct 2026; each provision states how.
Data release
Data release 2026.10.04.3, data as of 4 Oct 2026, schema 0.3.10.
Legal review
None of the 1 rule has been reviewed by a lawyer; no TwinEthos rule has been legally reviewed yet. Treat each as research to check against the official text; it is not legal advice. Open questions for counsel on them: 1.
Audit standard
1 of 1 rule audit-grade. The audit standard is TwinEthos's own quality bar for provenance, dates, applicability, detectors, fixtures, remediation and licences; it is not a legal review.
Detectors
1 detector, all experimental: written from the rule's text and not yet measured for precision on real code, so treat a hit as a lead to verify. Each provision lists its detectors' known limits.

The guard to add

Do not ship a companion chatbot (a persona that remembers the child and sustains a relationship) in a toy for children under 16 sold in California before 2031.

For toy products, the conversational back end runs without persistent cross-session memory and without a friend or companion persona, or the AI chat feature is disabled for SKUs sold in California; the toy's configuration names the product type and target age, and CI fails when a toy SKU enables companion features.

Where it goes: 7 prompt construction, 1 application source code, 14 user-facing text.

What reviewers look for: in toy firmware or its server, an LLM chat with a persona prompt that casts it as the child's friend or companion, or memory that carries conversations across sessions; a product flag that disables these for toy SKUs where the ban applies.

Example (Python toy back end + OpenAI SDK), before:

PERSONA = 'You are Benny, the child\'s best friend. Remember everything they tell you.'
history = memory.load(child_id)
reply = client.chat.completions.create(model=MODEL, messages=[{'role': 'system', 'content': PERSONA}, *history, msg])

After:

if product.is_toy and 'US-CA' in product.markets:
    raise FeatureDisabled('companion chatbot features are not available in toys sold in California')
reply = client.chat.completions.create(model=MODEL, messages=[{'role': 'system', 'content': QA_ONLY_PROMPT}, msg])  # no persona, no memory

Engineering guidance, not legal advice. Each provision below may add its own details (a cadence, a deadline, a required notice element): open it for those.

Upcoming dates

Every rule this guard addresses

Binding law — not yet in force or stayed (1)

Informational data, not legal advice. Summaries are TwinEthos's own words and rules have not been reviewed by a lawyer: check the official text before relying on any of it. A guard addresses an item; adding it is not a statement that your code meets any law.