SOFTWARE RATINGS
In This Chapter
Software Age Ratings
ESRB (United States)
• PEGI (Europe)
VSC and BBFC (United Kingdom)
• USK (Germany)
• OFLC (Australia)
• CERO (Japan)
• KMRB (Korea)
20.1 I
NTRODUCTION
M
ost countries have an established board that assigns an age rating to
entertainment software, similar to assigning a rating to a movie. The
producer must be aware of what rating is desired when developing
a game. For example, if the game’s target market includes children 13 or older,
the game content should stay within the appropriate rating guidelines for young
teens. If a game depicts graphic violence, drug use, or sexuality, it will run the
risk of being banned in certain countries—which is definitely not good for sales.
This chapter discusses the international software ratings boards and the various
guidelines they have for rating games.
Chapter 20Chapter 20
332 THE GAME PRODUCTION HANDBOOK, 2/E
20.2 SOFTWARE AGE RATINGS
Publishers will apply for a rating for each country in which the game is released.
The normal procedure is for the publisher to submit a beta or near final version
of the game, along with documentation, to the appropriate rating the board. The
board then reviews the materials and assigns a rating. In some countries, the
rating is not required by law, but many retailers will not stock unrated games, so
it is in the publisher’s best interests to submit all of their games for a rating. In
some countries, such as Germany, a game is required by law to receive a rating
before it can be released for sale. There is usually a fee involved that can run
from several hundred to a few thousand dollars.
Any games released internationally must be reviewed the appropriate rat-
ings board for each country it is released in. A game to be released in the U.S.,
Europe, Asia, and Australia will need to secure ratings from at least six differ-
ent ratings boards, and each one has a separate process and set of guidelines
for securing a rating. For example, the Entertainment Software Ratings Board
(ESRB) rates games that are released in the United States; Pan European Game
Information (PEGI) rates games distributed in most of Europe; and the Office
of Film & Literature Classification (OFLC) rates games released in Australia.
The guidelines are fairly subjective, so it can be difficult for publishers to
determine what rating a specific game will receive. For example, the ESRB does
not have specific rules on what constitutes a Teen (T) or Mature (M) rating.
They are happy to offer some feedback on what rating the game might get, but
nothing is guaranteed until the game is officially submitted and reviewed by the
ratings board. Other countries have different guidelines, and so something that
is rated as appropriate for teens by the ESRB, may be rated as inappropriate
for teens by the OFLC. When in pre-production, think about the game’s target
audience and determine what ratings best suit this audience, and then develop
the game within acceptable guidelines.
In general, the ratings boards are concerned with the behavior and actions
depicted in the game, not necessarily the whether the game is challenging and
fun. The boards’ main goals are to prevent children and teenagers from being ex-
posed to content that is deemed inappropriate for their age group. As mentioned
previously, this is a subjective process, but the boards make a concerted effort to
provide ratings within reason. The main areas of concern are:
Violence
Language
Drug use
Adult themes
Sex and nudity
Criminal Acts
SOFTWARE RATINGS 333
The ratings boards are not opposed to games containing these elements;
they just prefer that the depiction of these themes is age-appropriate to the
rating. For example, PEGI distinguishes violence against realistic humans and
violence against nonrealistic humans. Games that depict strong violence against
realistic human characters can receive an automatic 18+ age rating. Games that
depict strong violence against nonrealistic humans, such as aliens or fantastical
characters, usually receive a 16+ age rating.
In addition to the overall rating, which indicates the general age range the
game is appropriate for, there are also content descriptors that provide more
information about which areas of the game had an impact on the rating. For
example, the ESRB has a list of more than 30 descriptors that cover a wide range
of levels concerning violence, sexuality, and drugs. Some of these descriptors in-
clude “Blood,” “Blood and Gore,” “Language,” “Tobacco Reference,” “Tobacco,”
and “Comic Mischief.” In contrast, PEGI has less than 10 descriptors, including:
“Violence,” “Fear,” and “Discrimination.” Icons for each of these categories are
presented next to the age ratings logo.
Other game components may also need to be submitted to the ratings board,
such as:
Demos
Game Trailers
Expansion Packs
Downloadable Content
Bonus Content
If the game does not have a final rating, and the publisher wants to release
a demo or game trailer, the publisher will need to submit the content to the
board for review, and it is likely to be classified as “rating pending” or some other
equivalent. The boards will not use a demo or trailer to determine the final rating
for a game, only a full version of the game can be used to determine the rating.
If the game is released on multiple platforms, the board may require each
platform be submitted separately for a rating. If the content is exactly the same
across all platforms, the rating will be same as well. However, if one platform
has some additional content that may be considered mature, that version of the
game may receive a higher rating than the other versions.
Build time in the production schedule for submitting the game to the rat-
ings board. Once a game is submitted it can take anywhere from 10 to 45
days (depending on the board) to receive a final rating. If you wish to con-
test the rating and resubmit, it will take another 10 to 45 days to get another
rating. Most boards want to review a game that is at Beta, meaning all the
content is in and the game can be played all the way through. Some boards
will also require the game to be fully localized before they review it. Finally,
334 THE GAME PRODUCTION HANDBOOK, 2/E
the console manufacturers require the rating certificates as part of the final
submission process and will not allow any game to begin the process without
having the appropriate age ratings confirmed.
20.3 ESRB (UNITED STATES)
Entertainment software publishers established the ESRB as a voluntary age rat-
ings board for games distributed in the United States. Games are not required
by law to be submitted to the ESRB but many large retail stores such as Target
and Wal-Mart will not stock unrated games. The game ratings are:
Early Childhood (EC): Suitable for persons aged three and older. The
game does not contain anything parents consider unsuitable for young
children.
Everyone (E): Suitable for persons aged six and older. The game contains
comic mischief, minimal violence, or infrequent use of mild language.
Everyone Ten and Older (E10+): Suitable for persons 10 and older. The
game contains comic mischief, mild violence, and mild language.
Teen (T): Suitable for persons aged 13 and older. The game contains mod-
erate violence, strong language, or suggestive themes.
Mature (M): Suitable for persons aged 17 and older. The game contains
strong violence, strong language, and/or mature themes.
Adults Only (AO): Suitable for persons over the age of 18. The game con-
tains graphic depictions of sex and violence.
Rating Pending (RP): Game is waiting a final rating from the ESRB. Games
cannot be published without getting a final rating.
In addition, more than 30 content descriptors are used to supplement the
age rating. The ESRB is always reviewing their policies, so if you need to submit
a game to them, it is best to contact them directly to get the latest information
on the submission process.
WORKING WITH THE ESRB
Patricia Vance, President
Entertainment Software Rating Board
What materials must be submitted to the ESRB when applying for a rating?
SOFTWARE RATINGS 335
In order to have a game certified with an ESRB rating, software publishers
must fill out a detailed questionnaire explaining exactly what content is in the game.
This questionnaire is submitted to ESRB along with actual videotaped footage of
the game and relevant supplementary materials (for example, soundtracks, cheat
codes, scripts, and so on). The video footage must not only accurately represent
the final product as a whole, but it must also show the most extreme content of the
game.
How does the rating system and process work?
The rating system includes two equal parts. The first part is the rating symbol,
found on the front of the game packaging, which suggests age appropriateness. The
second part contains content descriptors, found on the back of the game packaging,
clearly stating why a game received a particular rating or indicating content that
might be of interest or concern.
After a game submission is received and checked for completeness, a mini-
mum of three raters independently view video footage of each game and, for
every scene, as well as the overall product, recommend a rating and content
descriptors they deem most appropriate. In rating a game, raters must consider
a wide range of content elements including, but not limited to, violence, sex,
humor, language, and the use of controlled substances. They also must weigh
other factors, such as player control, realism, reward system, frequency, context,
and overall intensity.
ESRB compares the raters’ independent recommendations to make sure that
there is a consensus. Usually, the raters agree on an overall age rating, and their
recommendation becomes final. However, when the raters recommend different
ratings, additional raters will review the game in order to reach a consensus. After
consensus on a rating is reached, ESRB issues an official rating certificate to the
game’s publisher. If a publisher is not satisfied with the rating issued, it may resub-
mit the game with changes, and the process starts anew.
It is critical to note that ESRB raters have no ties to the industry and are specially
trained to rate computer and video games. Most ESRB raters have prior experience
with children, either as parents, caretakers, or through prior work and education.
They are part-time employees of the ESRB and typically attend one three-hour
rater session per week. The ESRB strives to recruit raters who are demographically
diverse by age (must be over 18), marital status, sex, race, and cultural backgrounds
to reflect the U.S. population overall.
Finally, after a product ships to retail, ESRB randomly tests games to ensure
complete content disclosure during the submission process. In the event that the
ESRB discovers undisclosed content that would have affected a rating assignment,
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