336 THE GAME PRODUCTION HANDBOOK, 2/E
enforcement measures are taken, involving the imposition of significant fines and/or
corrective actions (for example, re-stickering or recalling the product).
How long does it take for the ESRB to evaluate a game and assign a rating?
When submission materials are complete, it takes an average of five business
days to evaluate a game and assign a rating.
At what point in the development process should a game be submitted for a rating?
A game should be submitted when all of the pertinent content is complete,
including graphics, sound effects, music, and dialogue. Often the product is submit-
ted prior to testing, which is one of the major reasons why ESRB requires content
be submitted on videotape.
Is a rating required from the ESRB in order to distribute entertainment software in the
United States?
The ESRB rating system is voluntary, although virtually all games that are sold
at retail in the United States and Canada are rated by the ESRB. This is thanks in
part to the commitment of major retailers not to carry games that have not been
rated by the ESRB. The video game industry created the ESRB in 1994 as its self-
regulatory body to ensure that parents and other consumers have accurate and reli-
able information about game content prior to purchase.
If developers are looking to achieve a particular rating, can the ESRB advise them on
what needs to change in order to achieve this rating?
After the ESRB informs the submitting company of the rating assignment, re-
flecting the consensus of the independent raters, the submitting company has three
choices:
■
Accept the rating assignment.
■
Consider making changes to the game and resubmitting materials to
possibly receive a different rating assignment.
■
Formally appeal a rating assignment before an industry-appointed
appeals board.
The submitting company might request a copy of the original rater consensus
report to understand what content in the game resulted in a specific rating assign-
ment, and any changes it should decide to make to the resubmitted product will be
at its sole discretion.
SOFTWARE RATINGS 337
Are there specific ESRB guidelines on exactly what differentiates a “T” or an “M”
rating?
There are general guidelines and a sense of parity about how certain types of
content relate to various rating categories, such as intense and prolonged scenes of
violence, nudity, sexual content, language, use of controlled substances, real gam-
bling, and so on. Beyond those obvious types of content, there are few hard and
fast rules when it comes to rating games. The manner in which a particular act is
depicted, the context in which it occurs, the intensity of the image itself, the reward
system, and the degree of player control all can greatly affect which rating category
and content descriptors are ultimately assigned to the game. And raters must use
their own judgment as to what content they feel is most relevant and important to
inform consumers about.
It is worth noting that, according to a survey regularly conducted by Peter D.
Hart Research Associates commissioned by the ESRB, parents overwhelmingly
agree with the ratings assigned by the ESRB. In 2004, parents agreed with ESRB
ratings 83 percent of the time, and 5 percent of the time parents thought they were
too strict. This level of agreement tells us that the ratings provide an accurate indica-
tion of game content and reflect the tastes and values of mainstream America, most
importantly those parents who use the system to help determine which games are
appropriate for their children.
20.4 PEGI (EUROPE)
PEGI, established in 2003, is a single rating system for most European countries.
The PEGI system is used in more than 25 European countries including France,
Spain, Italy, and the U.K. Please visit the PEGI website (www.pegi.info) for the
most current list of countries. PEGI also has a second component to their system
for online games. More information on this group can be found at www.pegion-
line.eu. Note that Germany does not use PEGI, instead they have established
their own national ratings systems called Unterhaltungssoftware SelbstKontrolle
(USK), their own national ratings system. The PEGI system has the following
ratings:
3+: Suitable for ages three and older. The product does not contain anything
that parents would find unsuitable for young children.
7+: Suitable for ages seven and older. The product contains things that might
be stressful or scary for young children, occasional violence against fantasy
characters, or nudity in a nonsexual context.
338 THE GAME PRODUCTION HANDBOOK, 2/E
12+: Suitable for ages 12 and older. The product contains graphic violence
against fantasy characters, nongraphic violence against realistic humans or
animals, moderate sexuality, or mild profanity.
16+: Suitable for ages 16 and older. The product contains graphic violence
against unrealistic humans or animals, strong sexual content, illegal drug use,
or the glamorization of crime.
18+: Suitable for ages 18 and older. The product contains graphic depictions
of violence against realistic humans or animals, graphic depictions of sexual
acts, glamorization of drug use, racism, or detailed information on how to
commit criminal acts.
They also have seven content descriptors: “Violence,” “Sex,” “Drugs,” “Fear,”
Discrimination,” “Bad Language,” and “Gambling.” The PEGI website contains
all the latest information on how to submit a game for a rating. Although the
PEGI system covers most of the European countries, exceptions must be noted
for the UK and Germany.
20.5 BBFC AND VSC (UNITED KINGDOM)
Although the United Kingdom uses the PEGI system, some games may also
need to be submitted to the British Board of Film Classification (BBFC) for
further classification. Games with strong adult content must be classified by the
BBFC before they can be legally distributed in the UK. An entity called the
Vide Standards Council (VSC) is responsible for determining if a game needs to
be submitted to the BBFC for further classification. If a game is required to be
submitted to the BBFC, but the publisher doesn’t comply and releases the game
anyway, the publishers and any retail stores stocking the game may be criminally
prosecuted. The BBFC classifications are as follows:
U: This is an advisory only rating. Suitable for all ages.
PG: This is an advisory only rating. Parental guidance is suggested.
12: This is an age restriction. No one under the age of 12 will be allowed to
buy a “12” rated product.
15: This is an age restriction. No one under the age of 15 will be allowed to
buy this product.
18: This is an age restriction. No one under the age of 18 will be allowed to
buy this product.
For the most current information on the submission process, please consult
the BBFC website (www.bbfc.co.uk).
SOFTWARE RATINGS 339
20.6 USK (GERMANY)
Germany has very strict age ratings that are assigned and regulated by its
national ratings board, Unterhaltungssoftware SelbstKontrolle (USK). Games
are legally required to be submitted for ratings. If software publishers do not
comply with this, they will be prosecuted. The USK ratings are as follows:
■
No age restriction:
■
Suitable for ages 6 and over
■
Suitable for ages 12 and over
■
Suitable for ages 16 and over
■
Not suitable for persons under the age of 18
Germany is well-known for its restrictive age ratings, and these ratings don’t
offer much insight as to what type of content is acceptable and what type of con-
tent is banned. If you are planning to release a game in Germany, it is better to err
on the side of caution when making decisions about game content. For example,
Germany is tough on hate crimes and symbols, particularly those associated with
Nazi Germany; in addition Germany is likely to ban games that contain extreme
blood and gore. In some cases, developers may create a separate version of the
game to be released in Germany that has altered content. Please consult the USK
website for the latest information on how to submit a game (www.usk.de).
20.7 OFLC (AUSTRALIA)
The Office of Film & Literature Classification (OFLC) is the ratings board
in Australia that assigns classifications to game. This board is regulated by the
Australian government, and all games are required to be classified before being
released in Australia. Their classifications are as follows:
■
G: Advisory rating that means the product is suitable for all ages.
■
G8+: Advisory rating that means the product is suitable for children ages 8
and up. Parental guidance is suggested for anyone under the age of 15.
■
M15+: Advisory rating that means the product is not suitable for children
under the age of 15.
■
MA15+: Age restriction that means children under the age of 15 cannot
view or buy the product unless in the company of a parent or guardian.
■
RC: This means the product has been refused classification. Any game that
exceeds the guidelines for an MA15+ rating will be refused classification and
cannot be distributed for sale in Australia.
340 THE GAME PRODUCTION HANDBOOK, 2/E
For current information on how to submit a game to the OFLC, visit their
website (www.oflc.gov.au).
20.8 CERO (JAPAN)
The Computer Entertainment Rating Organization (CERO) is the organization
that classifies games for release in Japan. Their rating categories are as follows:
■
All ages
■
Ages 12 and up
■
Ages 15 and up
■
Ages 18 and up
In addition, they have nine content descriptors used in conjunction with
these ratings for “romance,” “sex,” “violence,” “horror,” “gambling,” “crime,” “al-
cohol/tobacco,” “drugs,” and “language.” Their website, www.cero.gr.jp contains
the most up to date information on the submission process.
20.9 KMRB (KOREA)
The Korea Media Rating Board (KMRB) rates games for release in South Korea.
Their ratings categories are as follows:
■
All
■
18+
According to their website (www.kmrb.or.kr), they are concerned with con-
tent that might be undesirable for the following reasons:
■
Violating the constitutional and democratic order and damaging the national
honor.
■
Containing graphic depictions of violence or other taboo areas that are harm-
ful to public morals and might disturb the social order.
■
Damaging to the diplomatic relationships and national identity and, thereby,
adversely affecting the national interests.
Games will be banned in South Korea if the board considers the content to
be offensive. In 2004, Tom Clancy’s Ghost Recon 2, was refused a rating by the
KMRB and subsequently banned. The storyline involved a rogue North Korean
general who was trying to consolidate his power in North Korea. The ratings
board found this story to be too extreme and sensitive for the Korean market.
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