Yeah, but that's just BS - even many adults fail to distinguish between ads and content. So should they fall under COPPA too?
As in contract and rape law, people below an arbitrary cutoff age are presumed to be unable to give consent (or to even understand what "consent" means). Once beyond that age, the person is considered to be able to give consent, e.g. click "Agree" on a Terms/Conditions form or use a website with a very visible Privacy Policy link.
(Yes, I am joking.)