And Then There Was One… (Video Game Classification in the UK)

We interview Dirk Bosmans of PEGI and take a closer look at their ratings system.

I have often found myself the port of call for family members, friends or strangers who need advice on videogames. When browsing the shelves in my local purveyor of interactive entertainment I frequently help the unfortunate parent, grandparent or child who has a vague notion of what it is they are looking for, but just can’t find “that puzzle-y, cartoon-y thing about a man in a hat” (Professor Layton and the Curious Village in case it wasn’t clear). In many ways, I consider gamers the window into the gaming world for all those people who have just enough information to be a danger to the poor child who wanted Rock Band for Christmas, but got Rock Revolution instead.

It is with that in mind that I sought to make sense of the situation regarding videogame classification in the UK. The switch in the classification system has been pending for more than 24 months, and is currently scheduled to occur on Monday 30th July 2012.

As with films, videogames sold in the UK are classified and given an age rating by an authorised organisation. However, the classification of videogames is more complex than it is for films. All of this we, as gamers, know. No matter our age or background, at some point in our lives we have all had to consider the alphanumeric in that little coloured box on the cover of a videogame. For parents it is likely with child safety in mind; for teenagers it is whilst weighing up which sales assistant looks more susceptible to charm, or at least less inquisitive.

The important point is that the certificate awarded by the organisations performing videogame classification affects us all in some small way. How these organisations determine the age rating for a game and where to go for further information on a given game’s rating or content is not as widely known.

A little history

The Video Recordings Act (1984) required any videogame sold in the UK to be submitted for classification by a nominated organisation (at the time it was the British Board of Film Classification) where it contained:

• Gross acts of violence towards humans or animals
• Horrific behaviour or incidents
• Human sexual activity
• Criminal behaviour

Games devoid of the ‘controversial content’ listed above were exempt from classification, but in practice, almost all videogames were awarded an age rating because Microsoft, Nintendo and Sony made the Pan-European Game Information (PEGI) rating mandatory for all games on their platforms in Europe.

Complexity therefore arose from the fact that, for some time, both PEGI and the BBFC performed videogame classification. Though every game was rated by PEGI, and many displayed that rating, the BBFC rating had to appear on the box (in the UK) for those games with the aforementioned controversial content. Only the BBFC’s rating was legally enforceable, but that is about to change.

Following The Byron Review in 2008, the UK government undertook its own review of videogame classification in 2009. The outcome was that the Video Recordings Act (1984) was repealed and partially reinstated under the Video Recordings Act (2010). A significant part of this change was the decision that videogames would no longer be classified by the BBFC, and that PEGI would take sole responsibility. The implementation of this change has been delayed several times, to the frustration of both PEGI and UKIE (UK Interactive Entertainment – the videogame industry’s trade body in the UK), but is currently scheduled to occur, as mentioned, on Monday 30th July 2012.

So, what of PEGI and its rating system?

Pan-European Game Information

30 European countries, including the UK, use the PEGI classification system. In addition to this, Microsoft, Nintendo and Sony gaming consoles have integrated the PEGI system in their parental controls in Europe. Why is PEGI’s ratings system so popular, and how does it differ from that of the BBFC?

PEGI was created in 2003 to replace many of the different national classification systems that existed around Europe. As such, it was developed to be an amalgamation of all of these. That PEGI specialises in classification of videogames and offers multinational, multilingual coverage means that it has become very widely used. Further information on the system and a catalogue of ratings decisions can be found at.

The above ratings are accompanied by icons that pertain to the game’s content and themes. These are:

PEGI has also introduced PEGI Online, a seal of quality that recognises those games with online features that meet PEGI’s standards of safety and performance, particularly with respect to the protection of children. Another part of the PEGI system is PEGI Express, a fast-track system designed for Windows Phone apps, but that will hopefully be expanded to include other small digital games/content.

Further information on these subsidiaries of the PEGI classification system can be found at www.pegionline.eu and create.msdn.com respectively.

It should be noted that the PEGI Online label implies age restrictions affecting online features different to that indicated by the overall rating. This is an issue of data protection for online accounts and may therefore not be detailed upon the game’s packaging. Do not be surprised if a game rated PEGI ‘3’, ‘7’ or ‘12’ restricts online services to those above 13 years of age. Like many web services, the creation of an account for/by an under-age individual is a breach of the terms of service.

The rating information printed on the game packaging is accompanied, on PEGI’s website, by extended consumer advice in the form of some additional descriptions. PEGI ratings are determined in a slightly different way to BBFC ratings, and aim to:

• provide parents and caregivers with detailed recommendations regarding the age suitability of game content.

This point was addressed when I spoke to PEGI Communications Manager, Dirk Bosmans, who was keen to stress that “while it is frustrating for the 15 or 17 year-olds who can’t buy a particular game due to its rating, PEGI’s systems and ratings cater to parents”.

PEGI relies on a content declaration system when receiving games for classification. This takes the form of a 50-point checklist that the game’s publisher must complete (the form can be viewed here). Based on this checklist, a provisional rating is determined by the publisher and can be used in marketing materials for the game. An examination pack is sent to one of the PEGI administrators, who check the submission.

All provisional ratings awarded by PEGI are subject to review by their administrators, the Video Standards Council (VSC) or the Netherlands Institute for the Classification of Audiovisual Media (NICAM). Games with a rating of PEGI ‘3’ or ‘7’ are examined by NICAM, and those with a rating of PEGI ‘12’, ‘16’ or ‘18’ are reviewed by the VSC. It is the responsibility of these bodies to check that every review is in line with PEGI’s own classification criteria. See the links (above) for details of the PEGI criteria. If you would like to read more on the checks then the Games Rating Authority section of the VSC website is your best bet (videostandards.org.uk). In short, game content is investigated by an examiner who will play and view as much of the game and associated materials as they deem necessary to determine the rating.

Usually the provisional rating is confirmed and then accepted by the publisher of the videogame in question. This rating is the same in all countries that use the PEGI system. PEGI does not censor content, but publishers can initiate a consultation with the PEGI administrators to identify content that warranted a given rating and consider cuts/alterations to meet the criteria for a different age rating (higher or lower). This is similar to the way classification works for films and in a few cases results in different versions of the game/film being released in different countries.

Examples of such alterations, though not associated with PEGI’s rating of the games in question, include the European release of Grasshopper Manufacture’s No More Heroes, in which (like the Japanese version) blood was replaced with black ash to satisfy German ratings board, USK. Also, Bethesda Game Studios chose to rename Morphine as Med-X to avoid problems securing a rating in Australia.

Being reliant upon content declaration, PEGI requires all publishers to agree to the PEGI Code of Conduct as part of their agreement. This, the declaration form and the content suitable for each age rating are regularly updated by PEGI’s Experts Group, which includes representatives of the administrators and academic experts in the fields of child protection, psychology, etc.

It is incumbent upon the game publishers themselves to adhere to PEGI’s system. I asked Dirk Bosmans about this, and he explained, “Publishers are contractually obliged to adhere to the PEGI Code of Conduct. We have a great relationship with the coders who submit the games to us and they understand the importance of the PEGI system”.

Though not associated with PEGI, the infamous Hot Coffee mod for Rockstar North’s Grand Theft Auto: San Andreas that plagued its release in the United States was an obvious touchstone for our conversation about publisher honesty. Dirk is confident that a situation in which a publisher would willingly cheat would be unlikely to arise under the PEGI system since “The Code of Conduct details warnings and fines that can be levied if a publisher were to break their agreement with PEGI. It would leave the publisher with a mandatory re-rating of their game and a very costly withdrawal of the game from retailers”.

BBFC and PEGI

As the handover from the dual ratings system to a single PEGI system occurs it is important to understand how these systems differ from one-another. There are differences in how the games are rated, but the most obvious and pertinent difference for consumers is the rating shown on the packaging.

As with films, these ratings are used by retailers to determine who may purchase a game. However, for parents they are meant as a guide. There are no hard rules here, but, in general, the ages designated by the rating apply. Expect a game rated BBFC ‘U’ or PEGI ‘3’ to be suitable for all, whilst one rated BBFC or PEGI ’18’ to be suitable only for mature audiences.

Like the BBFC, PEGI provides additional information to help parents (and all consumers) decide whether a particular game is suitable. Until now, the Extended Classification Information provided by the BBFC has been generally more extensive and detailed than the additional descriptors provided by PEGI. This has often been pointed to as a strength of the BBFC’s system, and so I put this to Dirk. He explained the technical reason that PEGI was unable to provide such information: “The practicalities of including extended information prevented us from doing it. PEGI rates more than 2,000 games each year and provides ratings information in 26 different languages – that was just too much work”.

However, Dirk was able to say that extended information for the PEGI rating will be available very soon: “Providing extra classification information, like the BBFC did, was a requirement of PEGI being chosen as the single system for the UK. That information, in English, is coming sometime after the transition occurs next week and will be provided by the VSC under the Games Rating Authority (GRA)”.

One note of caution when drawing direct parallels between the BBFC and PEGI ratings –  they can sometimes vary for the same game. For example, Mass Effect was rated BBFC ’12’, but ’18’ by PEGI, clearly showing two very different interpretations of the same content. Digging a little deeper on this game, the BBFC Extended Classification Information states that the game contains “moderate violence”, qualified by the “futuristic setting” and its “undetailed” nature. The “moderate sex scene” in Mass Effect is described by the BBFC as “brief and undetailed” with “breast nudity in one version of the scene”. The fact that the sex scene is the result of “a series of choices about becoming more than friends with a colleague” is also noted to provide context.

PEGI also assessed Mass Effect and, as mentioned, rated the game ‘18’ with a content descriptor icon for violence. Their additional information is briefer than that of the BBFC, but also addresses the violent and sexual content. PEGI describe the “extreme violence” as “realistic looking”, whilst the “nudity of a sexual nature” is described as “sexual activity without visible genitalia”.

A second example came to my attention whilst writing this article. The ratings for SEGA’s 2012 game, Binary Domain were also different. The BBFC’s ‘15’ rating cites “strong violence” but tempered since “opponents are invariably robots” that “disappear from the screen” precluding any form of “post-mortem damage”. That “there is neither blood nor injury detail” was instrumental in avoiding the “particularly strong gory images” and “sadistic or sexualised violence” that are not allowed in ‘15’ rated games. “Moderate sexual banter” and “infrequent strong language” are mentioned only in passing and are deemed acceptable for a BBFC ‘15’ rating.

The BBFC are known to make a distinction regarding the victims of on-screen violence when considering its severity. Violence is regarded as more severe when perpetrated against humans and animals, meaning that, for instance, the beheading of an Uruk-hai (an orc-like creature) in The Lord Of The Rings: The Fellowship Of The Ring was permissible in a PG rated film.

PEGI rated Binary Domain at ‘18’ and included pictograms for Online Gameplay, Violence and Bad Language. The consumer advice classifies the violence as “extreme” and cites “strong language” as the other deciding factor in the games rating.

Anecdotally, differences in rating rarely occur, but where they do PEGI tend to award a higher rating (as above). Dirk was keen to avoid drawing direct comparisons between BBFC and PEGI ratings in specific cases, but he did have a more general point to make: “The BBFC and PEGI have separate systems for different forms of entertainment and, focusing on our won system, PEGI was built to deal with the specific nature of videogames. Sometimes it’s possible to look at the brevity or impact of (for instance) violence, but we have to consider that a player may have to re-play a section multiple times if it’s a hard section”.

He raises an interesting point. The Motion Picture Association of America (MPAA) – the BBFC’s counterpart in the United States – is notorious for detailing the number of times particular profane language can be used for a given rating. This just isn’t realistic for rating videogames where each player’s experience may be significantly different in content.

Both organisations, of course, award ratings as a reflection of their particular standards, but the above examples are illustrative to the consumer of the effect the forthcoming change could have on the games they buy, and play. Subjectivity in the age appropriateness of certain types of content or games can be minimised through the continued development of specific, objective criteria by experts referring to evidence and comparable materials. The consistent application of those standards through a system such as PEGI’s content declaration checklist can also help remove subjectivity. Differences between the various ratings boards will still exist, however, and so the adoption of a single classification system in the UK was vital.

There we have it, the situation regarding the classification of videogames in the UK and how those ratings are determined. Personally, I am glad that the recommendation of The Byron Review to consolidate videogame classification under one body was acted upon; two distinct systems could only cause confusion. The debate over which system is more suitable is moot at this point, the UK Government having decided that PEGI should be solely responsible for videogame classification some two years ago now. Be aware that, come Monday 30th July 2012, you can expect to see a lot more of the PEGI ratings on the cases of your videogames.

To coincide with the switch-over, GameBurst have published a podcast interview with UKIE CEO, Dr Jo Twist. UKIE have been instrumental in the changes discussed above and the interview is highly recommended. You can find it here: www.gameburst.co.uk

If you want to know more about PEGI, the BBFC, UKIE, the VSC or NICAM then please visit their respective websites, below. Also, take a look at the newly relaunched Ask About Games where parents and players can find a lot more help and guidance on videogames, classification and parental controls.

PEGI: www.pegi.info
BBFC: www.bbfc.co.uk
UKIE: www.ukie.info
VSC: videostandards.org.uk/VSC/ and videostandards.org.uk/GRA/
NICAM (English): www.kijkwijzer.nl/
Ask About Games: askaboutgames.com