Select Committee on Culture, Media and Sport Minutes of Evidence

Further supplementary memorandum submitted by the Video Standards Council

  This first section is from an article submitted to a French magazine.

1.   What is PEGI?

  PEGI stands for PAN-EUROPEAN GAME INFORMATION. The concept was first discussed at a meeting in Brussels in May 2001. This meeting was convened by the Interactive Software Federation of Europe (ISFE) and was attended by representatives from many European countries. The basic question that the meeting addressed was:

  Is it possible to design a pan-European system for the age rating of computer games?

  At this first meeting the representatives from the various countries explained their national position and it has to be admitted that the problems resulting from the varying national and cultural differences seemed insurmountable. However after 18 months of further meetings and discussions the problems were overcome and PEGI was born. Initially it operated in 16 countries of Europe (the major exception being Germany). It now operates in 28 countries of Europe.

2.   Can you explain to us what will consumers find on video game packaging?

  This is very simple. Consumers will see an age-suitability logo on the front of games packaging. Games will be rated at five different levels: 3+, 7+, 12+, 16+ and 18+.

  On the back of the packaging consumers will see up to two content descriptors indicating the main reason/s why the game was rated at a particular level. There are seven different content descriptors for violence, sex/nudity, discrimination, drugs, bad language, gambling and fear.

  The system relates to the content of a game and not to the degree of difficulty in playing the game.

3.   What is the benefit to consumers for this new system?

  The PEGI system of voluntary regulation will provide the public (particularly parents) across Europe with an indication of the age ranges for which a game is suitable and the age ranges for which a game is not suitable.

  It will also enable staff in games shops to be more helpful to customers when asked whether a game is suitable for a child or young teenager of a particular age.

  Parents and others having responsibility for the young are naturally concerned that children should not be exposed to anything unsuitable. Parents today have themselves grown up in an age of films, television and video and are probably fully capable of deciding what their children should watch. They have not grown up in an age of computer games and it is very difficult for them to check for themselves what exactly is contained in a game. This causes anxiety. The PEGI system will reduce this anxiety and give parents the confidence to decide on whether a game is suitable for their children.

4.   Who is in charge of administering the PEGI system on a daily basis?

  The system belongs to ISFE who have contracted the daily administration to the Netherlands Institute for the Classification of Audiovisual Media (NICAM). This is a Dutch body already responsible for the age rating of films, television programmes and videos in Holland. The Video Standards Council acts as NICAM's agent in the UK where a very large percentage of European games publishers are based. The VSC has been age rating computer games on a national basis since 1994.

5.   What does a games publisher have to do to rate a game?

  First of all the games publisher has to obtain a license to use the system from ISFE. Then the publisher has to register at least one "coder" who will be responsible for rating games on the PEGI on-line registration site.

  The on-line registration procedure is very straightforward. The coder is asked to give yes/no answers to a series of carefully worded questions relating to the content of the game. Once the answers are given the system automatically specifies a provisional age rating for the game and the descriptor/s to be used on packaging.

  Games given a 12+ rating are pre-examined by NICAM. Games given a 16+ or 18+ rating are pre-examined by the VSC before the rating is finalised. Games given a 3+ or 7+ rating are examined retrospectively by NICAM but there are proposals to examine these games in advance.

  Games at the 16+ and 18+ levels are examined by the VSC to deal with the UK legal situation. Under UK law some games (historically about 3-4%) are required to be legally classified by a Government appointed body and there are severe penalties for breach of the law. The VSC ensures that no game enters the PEGI system for the UK if it should be legally classified.

6.   Is it possible for a games publisher to complain about a rating given under the PEGI system?

  Yes, ISFE have an appeals procedure that a games publisher can use although it is to be hoped that most problems can be resolved by negotiation.

7.   What happens if a games publisher refuses to accept a rating after appeal?

  They would have a problem. The PEGI system is voluntary so they could always decide not to use the PEGI system. However this would probably not be sensible as the major games platform owners (Sony, Microsoft and Nintendo) are fully supportive of the system. A game publisher wanting to sell in the UK may also have problems as some games retailers will only stock games that have been properly rated.

8.   Culture is different in every european country. How can PEGI deal with these differences?

  This was seen as a major problem at the first meeting in May 2001. However as is very often the case it is a simple solution that solves the problem. This was the case for PEGI.

  For certain issues such as violence and drugs there was a general consensus across all the participating countries from the outset. For other issues such as bad language and sex/nudity there was not a consensus. This is where the content descriptors play their part.

  The descriptors indicate the main reasons why a game has been given a particular rating. If for example a game is given a 16+ rating for bad language and there are countries where bad language is not regarded as seriously as it is in the UK then the parent can make an informed buying decision and choose to ignore the 16+. The same is true where a game gets a higher rating for sex/nudity. There are certainly differing attitudes to sex and nudity across Europe but again the parent can see why a game has be rated at a particular level and if sex/nudity is not an issue then the parent can make an informed choice.


1.   Does the VSC administer PEGI only in the UK and NICAM administer PEGI in the rest of Europe?

  NICAM and the VSC jointly administer the PEGI system for all the 28 countries concerned. The VSC is not rectricted to the UK.

2.   How many examiners does the VSC have playing games, to verify that the publishers' self-assessment of their game is correct?

  The VSC has two people who examine games and NICAM has three. As you can see from the attached article extract the VSC pre-examines 16+ and 18+ games. Historically this has been 200-250 games each year (average of 4-5 each week).

3.   How long do examiners play the games for?

  To a great extent playing the game is only part of the examination process. If an examiner endeavoured to play a game from beginning to end without any help this could take 50-60 hours or more and even then the examiner would not see everything in the game (it is not like watching a film). Each time you play a game the experience is different, you are confronted by different scenarios and you see different things.

  Examining a game requires the assistance of the game publisher. The completion of the PEGI questionnaire is only the first step and it gives the examiner a good idea of what the examiner is looking for. In addition the publisher has to provide the examiner with a variety of aids such as cheat codes, walk throughs, God modes, saved games, video of game play (to mention a few). These aids give the examiner the ability to directly access any part of the game (from beginning to end). If during the examination process additional aids are needed these will be called for. Under the PEGI process the examiner will not complete an examination until all aids requested have been provided.

  It is entirely possible for a game publisher to "hide" something controversial in a game and not declare it. However many times the game is played an examiner may never find this controversial content (other than by luck). This applies to all examining bodies around the world. Under the PEGI system there are severe penalties for deliberately misleading an examiner (including a fine of up to €500,000). Since the beginning of PEGI there have been no examples of an examiner being deliberately mislead.

  I would say that on average it takes about 2-3 hours to examine a game. This can range from 30 minutes to 5-6 hours or more (sometimes spread over a period of time as more aids are called for). Some games are relatively easy to examine where the relevant content can be accessed quite quickly and other games are more difficult particularly where judgements have to be made at the dividing lines between 12+, 16+ and 18+.

June 2008

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