Culture, Media and Sport CommitteeWritten evidence submitted by the Film Distributors’ Association

1. Film Distributors’ Association (FDA) is the trade body for UK theatrical film distributors, the companies that release films in cinemas and promote them to audiences, propelling the film value chain into motion. The feature films brought to market by FDA’s diverse membership—ranging widely from international blockbusters to classic revivals; and from British films to productions of 42 other countries in 2013—account for 99% of UK cinema admissions. Lord Puttnam of Queensgate CBE is FDA’s President. Every theatrical film release is effectively a joint-venture between its distributor and the exhibitors willing to play it, while distributors’ launch campaigns typically involve a host of partners, suppliers and media.

2. Theatrical film distribution is a sophisticated, competitive and dynamic business that depends on product and the extent to which it connects with audiences. With 1% of the global population, the UK generates 7% of global cinema box-office receipts (£1.1 billion from 172.5 million admissions in 2012). The sector operates effectively and delivers a significant contribution to the economy in terms of revenue and jobs, as well as the consequent cultural and creative impacts. An economic multiplier effect applies: for every £1 spent on cinema tickets, at least a further £3 is pumped into the economy on directly related expenditure.

3. FDA welcomes the opportunity to contribute to the inquiry into Online Safety. Film distributors take child protection matters very seriously. Distributors have worked effectively and consistently to safeguard against children accessing inappropriate material throughout the last century. Some film distributors are established, family-trusted brands, known in their own right worldwide, while many others partner on particular projects with brands that appeal to children and young people. For many years, the whole industry has worked in collaboration with the independent British Board of Film Classification (BBFC), in helping to connect audio-visual works with age-appropriate audiences, and better inform those audiences about the content of the works on offer. We know that, in such matters, it is essential to retain public trust.

4. We should like to point out two areas of concern:

5. (i) Greater potential for consumer confusion:

Film distributors have always worked collaboratively with the BBFC, which celebrated its centenary in 2012. This relationship is relied upon by national and local government, while the published film-specific advice is trusted by the public—for home/mobile viewing as well as cinema visits. Last year’s announcement that the BBFC was to be responsible for the classification of content on mobile devices was greatly welcomed as ensuring consistency across devices and platforms.

However, this does further underline the potential for public uncertainty where two separate regulatory bodies are responsible for the classification of audio-visual products of significant similarity. Such confusion is most likely to arise when a feature film classified by the BBFC and a video game classified by PEGI are based on the same intellectual property (ie share a source of narrative and characters, such as The Hobbit). Inevitably this arises with many of the most popular franchises. Our concern is that parents will naturally make their decisions to purchase/access a video game based on their reliance on the long-established BBFC film classifications, perhaps unaware that the BBFC and PEGI approaches are quite different.

In response to consumer research, the BBFC provides clear and detailed information regarding the content of every film classified in the UK. This is relayed by film distributors and cinema operators on a film by film basis, so that parents may make more informed choices. The more fragmented the regulatory regime across entertainment properties, the greater the scope for user confusion.

6. (ii) Dangers inherent in the online piracy of audio-visual titles:

The film industry has always taken a robust approach to restricting young people’s access to inappropriate material—through the BBFC classification system, paid for title by title by film distributors.

As the technological innovations of video and, in turn, DVD placed more responsibility on parents, the industry continued to take seriously its obligation to provide clear information to enable parents to make appropriate decisions for their own children. Today, this is becoming increasingly difficult, as young people can access material online in the absence of parental supervision—rendering them vulnerable to what they may find. This problem may be exacerbated by the fact that young people are often more technically proficient than their parents.

FDA supports recent calls by Government and consumer groups for Internet Service Providers to filter (with age restrictions) and appropriately label the content they make available and monetise.

September 2013

Prepared 18th March 2014