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
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
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
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
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+.