Does the video game need a statutory BBFC classification or is it exempt under the Video Recordings Act?

Under the terms of the Video Recordings Act 1984, it is the responsibility of the individual game distributor or developer to decide whether a game requires statutory classification or not. The BBFC has no authority to make any decision about whether a game could be exempt.

Customers who are uncertain about whether a game is exempt can obtain further information through the PEGI UK offices administered by the Video Standards Council (VSC) vsc@videostandards.org . The PEGI questionnaire also details circumstances under which a game may lose its exemption. These include:

• Gross acts of violence towards humans or animals
• Horrific behaviour or incidents
• Human sexual activity
• Criminal behaviour

Following a review of both the voluntary and statutory systems in 2004, distributors should be aware that in some instances non-interactive material (trailers, ads, etc) may also lose exempt status.

Submission Requirements

The following is required for each video game submission;-

• A completed Video Games Submission Form
• A content complete build of the game on physical media (CD, DVD, memory card, etc.)
• An indication of the most contentious elements in the game and where in the game they occur
• Access to all cutscenes (see below)
• Access to any DVD style extras or unlockable content
• Supporting material that enables easy access to all parts of the game (cheats, save games, etc. See below)

Content complete code

The Video Recordings Act 1984 makes it clear that a classification certificate only applies to the work examined by the BBFC. While we accept that bug fixing and optimising will continue right up until a game is released, the BBFC requires a content complete version of the work. If changes are made to the content after its classification, the version released would not be the version classified and its sale or hire would be a criminal offence.

Submission of an incomplete version of the game will stop the submission proceeding. By signing the completed submission form, the signatory is confirming that the submission is content complete. Any costs or delays caused by the submission of a non-content complete version are the responsibility of the submitting company, not the BBFC.

Filling in the submission form

Video games must be submitted with a completed and signed Video Games Submission Form (two pages). In the case of a new customer, an account number will be created with the first submission. All other customers should ensure that the company name and account number are correctly entered on the submission form. If a company has more than one division the correct division name and account number must be entered on the form.

If the work has been submitted before, it might qualify for processing as a Distributor Change. It is essential that as much information as possible be provided at the submission stage to enable the previous version(s) to be identified

Additional Information

Please use this section of the form to highlight the most contentious issues in the game. It is important to indicate where in the game these occur and how they might be reproduced. If provided, gameplay footage should include examples of issues specifically mentioned here.

Cutscenes

The BBFC defines a cutscene as a non interactive, linear cinematic, whether pre-rendered or generated in real time. This is unlikely to include user-generated replays, fly-throughs and in-game hints and cut aways. However, scenes of over 15 seconds in length, or those which contain significant, contentious material are required. Where cutscenes are generated in real-time but vary in detail dependent on player input, only the generic versions of those cutscenes are required. The ability to change camera angle or perspective is unlikely on its own to prevent a sequence from being considered a cutscene.

Cutscenes can be provided either within the game itself (provided they are accessible via a debug menu) or on separate media.

Failure to provide direct access to cutscenes will stop the submission proceeding.

Unlockable content & Extras

Please ensure that any DVD style extras or unlockable content (i.e. bonus videos, trailers, image galleries etc.) are made available and give details on how these can be accessed. For any video extras, please also give an approximate total running time.

Where relevant, please ensure that any in-game unlockable content (i.e. extra levels, characters, mini games, weapons, power ups etc.) are also accessible.

Supporting Material

Examiners are required to sample game play throughout the game, not just at the beginning. A method must be provided to facilitate this whether that is cheat codes, a debug menu, save games etc.

Please provide the following, where relevant, to ensure that all parts of the game are easily accessible.

• Debug Menu (with instructions on activation and use)
• Command console (Typically for PC games, please include instructions)
• Cheat codes (god mode, level skipping, ammo, weapon unlocks etc)
• Walkthrough
• Save games (Please ensure that these are taken at regular points during the game and/or give access to all unlockable content)
• Synopsis / Script
• Details of game controls
• Manual

Failure to provide adequate supporting material will delay the submission.

Gameplay footage

Gameplay footage can be helpful in reaching a classification decision. If provided, please ensure that it is concise and is limited to the contentious elements of the game. Such footage should not normally exceed 60 mins running time

Copies of footage that may have been submitted to other ratings boards are perfectly acceptable and can be provided on either VHS, DVD or any other digital file format. (If supplied on VHS, please ensure it is of PAL standard)

IT Assessment

The BBFC’s IT department carries out a pre-viewing assessment of each game to ensure that the submitted version of the game is functioning as expected, is content complete, has access to the required cutscenes, has all the supporting material required and then determines the examining time which in turn determines the fee. If there are problems at this stage the IT department will contact the submitting company and delays to the processing may result. The nature of the video game submission will determine the length of time required for the examination process. A largely linear work with some degree of interactively will take less time than a highly interactive, complex game, and this will affect the fee charged.

Payment

Fees are calculated according to the tariff published on the BBFC website and also on request.

The BBFC operates a prepayment system for all works submitted. Customers can operate on a pro-forma invoice basis, or send money on account, which is run down as works are received and topped up as necessary. A ‘deposit against prepayment scheme’ is also possible. In all cases a VAT invoice is raised after examination has taken place, or when the secondary process has been approved.

If you have any questions about payments contact the Accounts department on 020 7440 0370/1 or email accounts@bbfc.co.uk.

Examination

Examiners apply the current BBFC Guidelines to propose the appropriate category for the work. The Guidelines are published on the website and available on request.

Advice screenings should be booked in the same way as classifications, by calling the BBFC Customer Helpline. A senior member of the examining team is available to discuss any issues with the customer before submission, and should be contacted through Examining Support Services (020 7440 1580).

Requesting a category

Specific category requests can be made on the submission form. The classification decision is reached following the BBFC Guidelines but, for example, if it is imperative that the work be awarded a ‘15’ category and it is assessed as ‘18’ the Board will contact the customer and discuss the possibility of a second viewing of the work by senior examining staff or cuts to the work to reduce the category. This has the benefit to the customer of saving the time which would be involved in receiving a classification higher than required and having to repeat the submission process.

Cuts required

The majority of works are passed without any cuts and with little difficulty regarding the category. However, if the work requires cuts you will be informed by letter. The letter gives a summary of the cuts and then gives a detailed description of each cut that is required. See below for an example.

At 108.5 mins	Example cut
Status	Cuts for Category
Ground	BBFC Guidelines
Issues	Sex/Nudity
Category with cut	15
Category without cut	18

A summary of the cuts will appear on the BBFC website once the work is classified.

Approval

The formal authority for approval of works under the provisions of the Video Recordings Act rests with the President of the BBFC. This authority is delegated to the senior staff of the BBFC – the Director, or in his absence, the Head of Policy and Business Development and the Senior Examiners. In this document they are referred to as “approvers”.

All category proposals and recommendations for cuts are considered by an approver. At this stage the work has been passed by the BBFC but not classified. For a work to be classified the category decision must be accepted by the company and the packaging approved if the company is a member of the VPRC scheme. If a recommendation for cuts is made the work will be seen by an approver to confirm that the cuts requested are necessary and correct.

Extranet/Interim clearance form and classification

If there are no issues the classification details should be accepted by the customer via the extranet or by signing and returning a copy of the Interim Clearance Form (ICF). In either case a final classification certificate will not be issued until the classification details have been accepted via the extranet or the ICF has been signed and returned.  A work may not be legally sold in the UK until the final classification certificate has been issued. Approval by the BBFC is not sufficient. The ICF does not act as a final classification certificate.

Packaging

Any customer submitting a game for classification is automatically entered into the Video Packaging Review Committee (VPRC) scheme; however, they may choose to opt out at any time. The committee approves the packaging of a work; the customer should ensure that they are able to submit three copies of the packaging in sufficient time to fit their release schedule. Customers wishing to opt out of the scheme should email helpline@bbfc.co.uk.

For customers that have opted out, each work will be classified as soon as the classification details have been accepted on the extranet or the ICF has been signed and returned; packaging need not be submitted.

Please refer to the packaging section for full details of how to submit your packaging.

Use of ‘TBC’ (To Be Confirmed) on pre-release promotional material

The BBFC understands that companies may need to produce pre-release publicity material for works which are awaiting or are in the process of receiving certification. In such instances, the BBFC will permit the use of ‘TBC’ superimposed over the category symbol in order to ensure that both retailers and the public are aware of the work’s interim classification status.

The category symbol must be present beneath the TBC and be the correct height and width in accordance with the VRA labelling regulations. Distributors may speculate on the potential category for the purposes of the exercise.

These TBC symbols can be downloaded from the BBFC website though distributors will need to contact the customer helpline (020 7440 0299) to obtain the link.

Distributors should aim to refresh packaging and publicity material once the final category has been confirmed.

Consumer Advice

The BBFC views the provision of Consumer Advice on packaging as very important. Our public opinion polling shows that the public wants Consumer Advice to help decide which games to allow their children to play. ELSPA and the Video Standards Council have agreed that the Consumer Advice which the BBFC produces for each work should be included in the packaging for ‘15’ and’18’ rated games. The Consumer Advice is provided with the category decision.

Titles on screen

Once the work has been approved an ICF may still not be issued if there is a query with the title on screen. It is the title on screen that is registered for classification (and not the one that may have been written on the submission form). If there is a discrepancy (except for minor mistakes in spelling or punctuation) between the title on the submission form and the title on screen, a Screen Titles Problem letter will be issued. The final classified title must appear on screen on the released product and on disc art/video labelling in accordance with the Labelling Regulations so this must be correct and conform to the Video Recordings Act. Please note that the classified title must use the Roman alphabet. The Board has a policy covering the use of potentially offensive language in titles.

Withdrawal Fee

Works submitted to the Board and subsequently withdrawn may incur a withdrawal fee. Please see the Notes to Fee Tariff for further information.

Retaining a copy of submitted games

Under the Video Recording Act the BBFC has a statutory duty to retain the original work as submitted to us. This statutory archive must be maintained indefinitely and for this reason we are unable to accept any submissions which are set to expire after any period of time or require any form of online authentication. However, offline copy protection mechanisms such as product keys or security dongles etc. are acceptable.

If you have any questions about the submission process for video games contact the IT Helpline on 020 7440 3299. This advice is free.