⚖️ New York’s "Warning Label" Mandate for Addictive Design

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The SAFE for Kids Act and the Surgeon General's Warning

On December 26, 2025, Governor Kathy Hochul signed S4505/A5346, effectively the "Stop Addictive Feeds Exploitation (SAFE) for Kids Act," making New York the first state to mandate cigarette-style mental health warning labels for social media platforms. The law specifically targets what it deems "predatory features"—including algorithmic feeds, autoplay, infinite scroll, like counts, and push notifications—that are designed to maximize engagement through dopamine-driven reinforcement. Under the mandate, platforms must display prominent, non-bypassable warnings designed by the Commissioner of Mental Health both at the initial point of access and periodically thereafter. The legislation draws a direct parallel to tobacco and alcohol regulations, citing a 2023 Surgeon General's advisory that linked excessive use (over three hours daily) to doubled risks of anxiety and depression among adolescents.

The "Addictive" Definition and the Burden of Purpose

For founders building consumer-facing apps, the critical insight lies in the law’s broad definition of an "Addictive Social Media Platform." The statute covers any website or app that provides these features as a "significant part" of its service. However, it includes a crucial "valid purpose" exemption: a feature like autoplay or push notifications may be exempt if the Attorney General determines it serves a purpose unrelated to prolonging use. This creates a complex legal gray area for startups. For example, a push notification for a security alert or a vital health update is likely exempt, but a notification meant to lure a user back to a content feed is not. As social media "warning labels" move from an advisory suggestion to a codified state requirement, platforms will face a $5,000 civil penalty per violation, which can scale rapidly when applied to a large user base.

The "Warning Label" law represents a shift toward friction-based regulation, where the state intentionally slows down user engagement to protect public health.

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