Comparing Classifications: feature films and video games 2010 & 2011

Office of Film and Literature Classification Comparing Classifications 2010 & 2011

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Office of Film and Literature Classification Comparing Classifications 2010 & 2011

Comparing Classifications: feature films and video games 2010 & 2011

Office of Film and Literature Classification Te Tari Whakarōpū Tukuata, Tuhituhinga 4th Floor, BP House 20 Customhouse Quay PO Box 1999 Wellington 6140

Phone 04 471 6770 Fax 04 471 6781 Email [email protected] Web www.censorship.govt.nz

ISBN: PDF 978-0-477-10397-8

May 2013

Acknowledgements

The Classification Office is grateful to Nokuthaba Sibanda and Lara Wieser from the School of Mathematics, Statistics and Operations Research at Victoria University of Wellington who worked with us in 2009 to develop the scoring methodology and the analytical approaches used in this report. We are also grateful to Mike Camden of Statistics NZ who helped us in 2010 to present the data graphically. We also thank the Film and Video Labelling Body in New Zealand, and our film and game classification colleagues in the countries selected for comparison.

This report was prepared by Kate Ward and Henry Talbot of the Information Unit at the Office of Film and Literature Classification, Wellington, New Zealand. ©2013

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Executive Summary ______5 Introduction ______7 The Classification System in New Zealand ______8 Jurisdictions for Comparison ______10 Methodology ______11 Terminology ______11 Data ______11 Master Lists ______11 Classification strength scores ______12 Data analysis ______15 Explanation of Bubble Charts ______15 Film Results ______16 New Zealand and Australia ______17 New Zealand and the ______19 New Zealand and the United States ______21 New Zealand and Ontario ______23 New Zealand and Singapore ______25 Summary – comparing films ______27 Game Results ______28 New Zealand and Australia – games ______29 New Zealand and United States – games ______31 New Zealand and Ontario - games ______33 New Zealand and pan- - games ______35 New Zealand and Singapore - games ______37 Summary – comparing games ______39 Comparisons of strength averages between 2008/09 data sets and 2010/11 data sets ______40 Appendix A: Guide to Classification and Ratings Systems for Films and Games ______41 Entertainment Software Ratings Board [games rating system used in the US and Ontario] ______41 Pan-European Game Information (PEGI) [games] ______42 British Board of Film Classification (BBFC) [films] ______44 Motion Picture Association of America (rating system known as CARA) [films] ______45 Ontario Film Review Board [films] ______46 Singapore Media Development Authority [films] ______47 Australian Classification Board [films and games] ______48 Office of Film and Literature Classification and the Film and Video Labelling Body [films and games] ______49 Appendix B: Films and games used in this study ______50 Films ______50 Games ______54 Appendix C: 2008/09 Strength Scores ______57 Office of Film and Literature Classification Comparing Classifications 2010 & 2011 Executive Summary

Purpose of the research

The classifications assigned to films and games by different countries are substantially variable as are the symbols, names and meanings used on classification labels. Nevertheless, it is interesting to compare New Zealand classifications with those of other jurisdictions, to find out what is similar and what is different between us.

Methodology

To enable comparisons to be made, we developed and applied a scoring system. Classifications were listed and ranked in increasing order of age restriction. A numerical score was attached to each classification, with less restrictive ones receiving lower scores. In general, classifications allowing parental/caregiver accompaniment below a given age were considered weaker than those that have a legally enforceable age restriction.

228 films and 128 games are included in the analysis. The film titles were mainly for cinematic release, but in some jurisdictions were only released on DVD. Respectively, 99 films and 115 games were classified in all of the jurisdictions compared.

The comparisons for film show that:

 In general, the greater range of age restrictions available in New Zealand (eg: R13, R15, R16, etc) means that decisions can be tailored more than in jurisdictions with catch-all classifications for content targeted at an adult audience: for example, MA15+ in Australia, or R in the United States.  Australian classifications are inconsistent with New Zealand’s largely because of the differing principles the systems are based on which allow for parental choice in Australia at the MA15+ level, where in New Zealand these films are more likely to receive an age restriction of R16. In the comparison with Australia, a large group of films, 97 out of 224, is restricted to people 16 and over in New Zealand but has the parental accompaniment MA15+ in Australia. New Zealand’s closest classification equivalent to MA15+ is RP16. The only film classified RP16 during the period of the study was by the Film and Literature Board of Review who overturned the Classification Office R16 decision for the film 127 Hours.  While overall the United Kingdom and New Zealand systems are equally strong, the British Board of Film Classification is more likely to negotiate cuts than ban outright compared to the New Zealand Classification Office. New Zealand is a small market of 4 million and distributors and producers may not be as motivated to make cuts for a lower classification as they are for the United Kingdom market of 63 million people.  The strength of the New Zealand system tips closer to that of the United States because 18 films in the sample are classified M (unrestricted) in New Zealand, but rated R in America. The reason is most likely because sexual content is assessed differently between the two systems. In the United States, R was applied to 91% of the titles and is the only option for films intended for an adult audience, apart from NC17+. NC17+ does not appear at all

5 Office of Film and Literature Classification Comparing Classifications 2010 & 2011

for the 134 titles in the data set, and was therefore not applied to 18 films classified R18 in New Zealand — all rated R in the United States. These films included Drive, , The Human Centipede, and Harry Brown.  While 180 film titles formed the data set for comparison between New Zealand and Ontario, just three (less than 2%) are fully age-restricted in Ontario. Ontario and Australia are on a par as the most liberal systems in the comparison group. In Ontario, this is mostly due to the high use of their 14A classification which, similar to Australia’s MA15+, is a parental accompaniment restriction.  The relative strength of the Singaporean system compared to New Zealand’s is due to a number of films receiving an M (unrestricted) classification here, but classified restrictively in Singapore as either NC16, M18 or R21. Many of these films contain sexual references and material of a sexual nature that may be less acceptable within the Singaporean cultural context.

The comparisons for games show that:  Overall, the New Zealand game classification system is more restrictive than Australia’s during the period under comparison. While New Zealand made frequent use of its R18 option for games — other than banning games — no high-level restriction was available in Australia during the period. Australia has since introduced an R18 for games. Although it’s a small subset of the total sample, the majority of games classified M in New Zealand were classified MA15+ in Australia. Almost all of the games classified R16 in New Zealand were classified less restrictively as MA15+ in Australia.  Similarly, the United States’ ESRB system is also less restrictive than New Zealand’s system. The only classifications that have equivalent strength between the two systems are the New Zealand unrestricted M and the United States Teen classification. Of the 19 Teen games in the sample of 130, 15 were restricted in New Zealand.  While New Zealand and Ontario film classification systems are at odds, the effect of enforcement of ESRB ratings in Ontario strengthens their game classification system to equivalency with New Zealand’s. 71% of the games compared between the two countries are classified relatively consistently.  Where it is not enforced, but treated as advisory only, the PEGI system is much less restrictive than New Zealand’s. The decision whether to enforce PEGI ratings at point-of-sale is made at government level. For example, in the United Kindgom, which switched to the PEGI system in 2013, the ratings will be enforced at point- of-sale for 12, 16 and 18. In Ireland, anything receiving a PEGI 18 is assessed by the Irish Film Classification Office (IFCO) against Irish classification criteria, and may be banned or released with an IFCO classification. Otherwise, in Ireland, videogames are exempt from classification, but the country does support the PEGI system. Germany is notable for remaining outside the PEGI system.  The Singaporean system is less restrictive than New Zealand’s in spite of 67 ‘M18’ restricted titles, compared to 28 R18s in New Zealand. The overall comparison could be skewed by the number of games in the sample that were ‘approved for distribution’ – in other word, not rated by the MDA. The basis for Singapore’s Media Development Authority’s decision whether to classify particular games or just approve them for distribution is unclear at the time of writing, but games approved for distribution can carry another jurisdiction’s advice, for example, ESRB labels. Of the 62 games classified R16 in New Zealand, half were restricted to 18 years and over by the MDA, indicating a more restrictive system than ours in some respects.

6 Office of Film and Literature Classification Comparing Classifications 2010 & 2011 Introduction

The Office of Film and Literature Classification (OFLC) is an Independent Crown Entity that classifies publications that may carry restrictions in New Zealand. The OFLC assesses publications against criteria in the Films, Videos, and Publications Classification Act 1993 and applies an unrestricted or restricted classification, or bans objectionable material.

The purpose of New Zealand’s classification system is to prevent injury to the public good. Classifications also help the viewing public to make informed choices about films and games they wish to see and play. The restricted classification label displays the age below which the film or game may not be supplied or exhibited, and labels also provide notes about content that may be of concern to viewers, such as offensive language or violence.

The classifications assigned to films and games by different countries are substantially variable as are the symbols, names and meanings used on classification labels. In this study we have developed a scoring system to assist with comparisons of the relative strengths of other countries' classifications in relation to ours. This interpretive approach may be problematic from the perspective of readers in other jurisdictions, and so we have provided the data behind our analyses and findings for others to adapt as they see fit.

In 2010 we piloted this system of comparison with 2008 and 2009 classifications from a similar group of countries. Where summary comparisons with the current data sets can be made, the findings are presented in summary format in Appendix C.

7 Office of Film and Literature Classification Comparing Classifications 2010 & 2011 The Classification System in New Zealand

The OFLC is mainly concerned with films and video games that may contain restricted or objectionable content under the Films, Videos, and Publications Classification Act 1993. The legal test of an objectionable publication is whether it 'describes, depicts, expresses, or otherwise deals with matters such as sex, horror, crime, cruelty, or violence in such a manner that the availability of the publication is likely to be injurious to the public good'.

Most films and games examined by the OFLC are submitted by commercial parties through the Film and Video Labelling Body (FVLB), which also has responsibility for issuing classification labels. Films and games can also be submitted to the OFLC by enforcement agencies such as the Censorship Compliance Unit of the Department of Internal Affairs, New Zealand Customs, the Police, the Courts, or by members of the public with permission from the Chief Censor.

After examining a publication, the OFLC can assign one of the following types of classifications: a) unrestricted b) objectionable, or c) objectionable except in one or more of the following circumstances: i) if the availability of the publication is restricted to persons who have attained a specified age ii) if the availability of the publication is restricted to specified persons or classes of persons, or iii) if the publication is used for one or more specified purposes

Classifications are legally enforceable in New Zealand. For example, it is illegal to make a film or which is classified R18 available to someone who is under 18 years of age.

The Films, Videos, Publications and Classification Regulations 1994 instituted a system in which unrestricted classifications given to films by the Australian Classification Board (ACB) in the first instance, or the British Board of Film Classification (BBFC) if no Australian classification exists, are adopted in New Zealand. That is, a G, PG or M in Australia, or a U, PG or 12/12A in the UK, will be automatically labelled with the New Zealand symbols of G, PG or M. This is called cross-rating and is performed by the FVLB. Games with unrestricted level content are exempt from the labelling requirements. This means unrestricted games may be supplied to the public showing classification labels from other jurisdictions — a situation that causes some consumer confusion. However, if distributors and suppliers wish to affix a New Zealand classification label to an unrestricted level game, then the cross-rating system is applied in the same manner as for films.

For films not previously classified in Australia or the UK, a FVLB viewing panel assesses the film and assigns a rating, or submits it to the OFLC for classification.

8 Office of Film and Literature Classification Comparing Classifications 2010 & 2011 Figure 1 illustrates the process the FVLB must follow when a film, DVD or game is submitted for classification.

9 Office of Film and Literature Classification Comparing Classifications 2010 & 2011 Jurisdictions for Comparison

For film classification comparison purposes, three jurisdictions with government-appointed regulators were selected:

 The Australian Classification Board (ACB)  The Ontario Film Review Board (OFRB)  The Singapore Media Development Authority (MDA)

In addition, two countries with industry-appointed regulators were selected:

 The British Board of Film Classification (BBFC)  The Motion Picture Association of America (MPAA)

For video game classification, the following organisations were selected for comparison.

Two are government-appointed regulators:

 The Australian Classification Board (ACB)  The Singapore Media Development Authority (MDA)

Two are industry run:

 Pan-European Game Information (PEGI) as used across a large number of European countries  Entertainment Software Rating Board (ESRB) which is used in the USA, and in Ontario where some of the ratings are enforced

Information on the meaning of the classifications used by each of the organisations selected for comparison is provided in Appendix A along with links to official websites.

10 Office of Film and Literature Classification Comparing Classifications 2010 & 2011 Methodology

Terminology

‘Classifications’ and ‘ratings’ have the same meaning in this report. DVD and film are also interchangeable terms, as are games and video games.

Data

The data used in the study was gathered by OFLC staff from the websites of each of the comparison organisations for films and games classified in 2010 or 2011, and from correspondence with staff of those organisations. The data gathered was the film or game title and the classification.

As other jurisdictions are compared to New Zealand rather than to each other, except in summary form, the sample for comparison is films and games classified in New Zealand. We found little variation across the jurisdictions of G, PG, and UK ‘U’ titles so have excluded most G and PG titles from the comparisons.

It should also be noted that unrestricted film titles in New Zealand generally adopt the classification of the Australian Classification Board, and that unrestricted games in New Zealand do not require a New Zealand label and mostly carry an overseas label in this market.

Also excluded from the lists for comparison are films passed with cuts. Cuts for theatrical release and DVD/Blu ray release are reasonably common in the United Kingdom and Singapore. For example in Singapore during the period under comparison, films cut for release included Black Swan, The Girl with the Dragon Tattoo, Harry Brown and Enter the Void. In the United Kingdom films cut for release included Daybreakers, The Expendables, and 3D Sex and Zen: Extreme Ecstasy. Cuts may be agreed by distributors in those jurisdictions for the sake of a lower classification. This is also the case in New Zealand, but no films in the sample under consideration were affected.

Master Lists

The master lists in Appendix B are the data sets used for comparisons. The film titles were mainly for cinematic release, but in some jurisdictions were only released on DVD.

228 films and 128 games are included in the analysis.

Respectively, 99 films and 115 games were classified in all of the jurisdictions compared.

11 Office of Film and Literature Classification Comparing Classifications 2010 & 2011 Classification strength scores

A numerical score, referred to as a 'classification strength score', is used for comparisons to be made.

In the following tables, the classifications are listed and ranked in increasing order of age restriction. A numerical score is then attached to each classification, with weaker ones receiving lower scores.

In general, classifications allowing parental/caregiver accompaniment below a given age are considered weaker than those that have a legally enforceable age restriction. The exceptions are highlighted in yellow in Table 1: R (MPAA) and 12 (BBFC), and 18A (OFRB) and R13 (OFLC), which were given the same scores. This overlap was due to the likely restrictiveness in practice of R and 18A in the jurisdictions concerned. For example, it is unlikely that many under 13 year-olds would be allowed to see an 18A film in Ontario.

As restricted classifications are legally enforceable in New Zealand the classification strength scores in the following tables reflect this. The score is relative to the age below which a restriction applies. For example, R13 has a score of 11 and R15 a score of 13; R16 has a score of 14 and R18 a score of 16.

Classifications where parental accompaniment is a requirement are judged two points stronger than unrestricted films intended for a mature audience. That is, the unrestricted M (ACB and OFLC) has a score of 3, while the UK parental accompaniment classification 12A is scored 5.

In scoring game classifications, PEGI's are all in the unrestricted category as the age recommendations are not enforced in most countries that use the system. Otherwise, the same assessments as for films were applied, eg, the lowest parental accompaniment category is ACB's MA15+ which, to be consistent with film classifications, has a classification strength score of 8.

Those interested in a deeper understanding of the cultural, political and legal bases of the respective classifications systems should reference the codes/standards/criteria used for assessment that are published by the classification bodies concerned.

In this comparison, we included Singapore because according to the 2006 census, around 150,000 New Zealanders identified as Chinese, 111,000 of whom were born in Asia. From this, we assume that an Asian classification system is as valid to include for comparison as our traditional European and American comparison jurisdictions.1

Disclaimer Weighting classifications using a scoring system could be considered a subjective exercise, and differently weighted classifications will produce different results to those presented here. Nevertheless, we are confident that the weighting system we have applied is reasonable given all the circumstances under comparison. In particular, legally enforceable age restrictions and those allowing parental choice or accompaniment are treated differently.

1 http://www.stats.govt.nz/browse_for_stats/people_and_communities/asian-peoples/asian-ethnic-grp-profiles-06-tables.aspx

12 Office of Film and Literature Classification Comparing Classifications 2010 & 2011 Table 1: Classification strength scores for feature film classifications

2010-11 Jurisdiction Classification Strength Score Unrestricted Australia G 1 New Zealand G 1 Ontario G 1 UK U 1 USA G 1 Singapore G 1 Australia PG 2 New Zealand PG 2 Ontario PG 2 UK PG 2 USA PG 2 Singapore PG 2 USA PG-13 3 Singapore PG13 3 Australia M 3 New Zealand M 3 Parental accompaniment (a restricted category) UK 12A 5 New Zealand RP13 6 Ontario 14A 7 Australia MA15+ 8 New Zealand RP16 9 USA R 10* Ontario 18A 11* Restricted UK 12 10* New Zealand R13 11* New Zealand R15 13 UK 15 13 New Zealand R16 14 Singapore NC16 14 USA NC-17 16 Australia R18+ 16 New Zealand R18 16 Ontario R 16 UK 18 16 Singapore M18 16 Singapore R21 19 Banned NZ Objectionable 25 UK Rejected 25 Australia RC 25 Singapore NAR 25

*The 'overlap' in weighting is due to likely restrictiveness of each rating in practice: eg the likelihood that many under 13 year-olds would actually see an 18A rated film is low

13 Office of Film and Literature Classification Comparing Classifications 2010 & 2011 Table 2: Classification strength scores for video game classifications

2010-11: Jurisdiction Classification Score Unrestricted Singapore Approved/General 1* ACB G 1 ESRB Early Childhood 1 OFLC G 1 PEGI 3 1 ACB PG 2 ESRB Everyone 2 OFLC PG 2 PEGI 7 2 ESRB E10+ 2.5 PEGI 12 3** ACB M 3 OFLC M 3 ESRB Teen 3 Singapore Age Advisory 4*** PEGI 16 4** PEGI 18 6** Parental accompaniment (a restricted category) ACB MA15+ 8 ESRB (USA) Mature 17+ 9** Restricted OFLC R13 11 OFLC R16 14 ESRB (Ontario) Mature 17+ 15 Singapore M18 16 ESRB AO 16**** OFLC R18 16 Banned ACB RC 25 OFLC Objectionable 25 Singapore NAR 25

*MDA classified games do not require a label unless they're given an Age Advisory or M18 rating. If the rating on their database is ‘General’, it means the game has been approved for distribution and may carry a label from another jurisdiction. ‘General’ is not advice about the game’s suitability **Non-statutory/voluntary systems. However encouragement/compliance to not sell to underage children is said to be high in the United States, and encouraged in Europe. ***Similar to New Zealand’s 'M'. In Singapore, retailers are encouraged to exercise responsibility and not to sell to young people. ****While AO is a non-statutory classification in the USA, it is given the same strength as 18 age restrictions as there is strong (mostly) commercial/retail compliance. It is enforced in Ontario.

14 Office of Film and Literature Classification Comparing Classifications 2010 & 2011 Data analysis

The film and game titles were placed in an ‘Unrestricted’, ‘Restricted’ or 'Banned' category. A title was considered ‘Restricted’ if there was a definitive age restriction or an age restriction below which parental accompaniment was required.

The following approaches to representing the data were undertaken:

1. Graphical representations (bubble charts) comparing jurisdictions were created using the classification strength scores. 2. Cross-tabulations were used to identify similarities and differences between OFLC film classifications and those of other jurisdictions (Tables 3-7), and OFLC game classifications and those of other jurisdictions (Tables 8-12).

Assessment of the comparative strengths and weaknesses of the classification regimes is based on the classification strength scoring system adopted by the OFLC for this analysis.

Explanation of Bubble Charts

A bubble chart represents three sets of data. It is a variation of a scatter chart (which represents two sets of data). The bubble charts represent classification strength scores given to film or game titles between any two jurisdictions. For example, one bubble will represent all titles classified R16 in New Zealand and 15 in the United Kingdom. Each bubble also represents a number of titles – the bigger the bubble, the more titles are represented. The bubbles are distributed according to their classification strength score in each jurisdiction. The strength score scale is on the vertical and horizontal axes.

The straight red line dissecting the bubble chart is an equality line. If a bubble is on the equality line then a certain amount of titles (represented by the size of the bubble) were given the same classification strength score in both jurisdictions: for example, R18 in New Zealand and 18 in the United Kingdom.

15 Office of Film and Literature Classification Comparing Classifications 2010 & 2011 Film Results

The following charts and tables show the relative strength of the New Zealand film classifications compared to Australia, the UK, Ontario, the US and Singapore. See Appendix A for details about the classification systems used.

228 titles with New Zealand classifications ranging from M to objectionable made up the data set for comparison. G and PG classifications were excluded as largely irrelevant to the work of the New Zealand Classification Office whose job is to deal with material that may need restriction in order to prevent injury to the public good. Note that not all films in the master list of 228 can be compared jurisdiction by jurisdiction.

The sample of 71 New Zealand M classifications used in the comparisons were either assigned by the Film and Video Labelling Body’s viewing panel, who apply the classification principles and criteria in section 10 of the Films, Videos, and Publications Classification Regulations 1994; or by the Office of Film and Literature Classification applying classification criteria and principles as set out in section 3 of the Films, Videos, and Publications Classification Act 1993. There is one restricted film in the data set that was classified by the Film and Literature Board of Review. Board of Review members are also required to apply the criteria in section 3 of the Films, Videos, and Publications Classification Act 1993 to their decision-making.

See Appendix B for the films data set.

16 Office of Film and Literature Classification Comparing Classifications 2010 & 2011 New Zealand and Australia

Chart 1: Comparison of Relative Strength of New Zealand and Australian film classifications

Chart 1 compares the relative strength of New Zealand and Australian classifications. The chart shows:

 Of the 224 films compared, 44 were classified M in both Australia and New Zealand.  A small group of films was classified R18 in both countries.  A slightly larger group of films that New Zealand classified R18, Australia classified MA15+. The MA15+ strength score is 8 cf. 16 for the New Zealand R18.  A large group of films that is age restricted to people 16 and over in New Zealand has the parental accompaniment MA15+ in Australia.  New Zealand’s closest classification equivalent to MA15+ is RP16. The only film classified RP16 was decided by the Film and Literature Board of Review overturning the Classification Office R16 decision for the film 127 Hours.  Circled at the top of the chart is a film banned in New Zealand, but released MA15+ in Australia. Megan is Missing is a controversial film as some interpret the sexual violence depicted in it as cautionary, others as exploitative.  New Zealand banned four films that are available in Australia (see New Zealand strength score 25 on the chart above). They are: Megan is Missing MA15+, Hooking Up, I Spit on Your Grave, and Sick Girl – all R18 in Australia.

17 Office of Film and Literature Classification Comparing Classifications 2010 & 2011 Chart 1 was derived from the following data*:

NZ Aus NZ Score Aus Score Count M G 3 1 1 M M 3 3 44 M MA15+ 3 8 16 M PG 3 2 9 RP16 MA15+ 9 8 1 R13 M 11 3 2 R13 MA15+ 11 8 7 R16 M 14 3 10 R16 MA15+ 14 8 97 R18 MA15+ 16 8 20 R18 R18+ 16 16 13 BANNED MA15+ 25 8 1 R18+ BANNED 25 16 3

*Classifications in the table above are considered relatively consistent when they are less than or equal to 3 strength points of each other, and relatively inconsistent when they are more than 3 strength points of each other. Consistent classifications are highlighted in blue in the data table above. Australian classifications are inconsistent with New Zealand ones largely because of the differing principles the systems are based on which allow for parental choice in Australia at the MA15+ level, where in New Zealand these films are more likely to receive an age restriction of R16.

In Table 3, of the 107 films classified R16 in New Zealand, 91% have a parental accompaniment MA15+ classification in Australia and the remaining 9% are classified unrestricted ‘M’, indicating that overall the Australian classification system is more liberal than the New Zealand one.

Table 3: New Zealand classifications compared to Australian classifications

n=224 Australia Key No. of titles 1 9 56 142 16 Unrestricted G PG M MA15+ R18+ Partial Restriction* 70 M 1 9 44 16 Restricted 1% 13% 63% 23% Banned 1 RP16 1 100% *For theatrical release films: restricted 9 R13 2 7 unless accompanied by a parent or guardian while viewing the film 22% 78% 107 R16 10 97 *For films on video (DVD/Blu-ray): restricted unless accompanied by a NewZealand 9% 91% parent or guardian 33 R18 20 13 61% 39% 4 Ban 1 3 25% 75%

18 Office of Film and Literature Classification Comparing Classifications 2010 & 2011 New Zealand and the United Kingdom

Chart 2: Comparison of New Zealand and United Kingdom film classifications

Chart 2 compares the relative strength of New Zealand and United Kingdom classifications. The chart shows:

 Of the 187 films compared, most cluster around the equality line showing that they are classified relatively consistently between the two countries.

 33 films that were classified 15 in the United Kingdom (a legal restriction) were classified M (unrestricted) in New Zealand. Essentially, these differences make the United Kingdom system more restrictive.

 One film banned in New Zealand is classified 18 in the United Kingdom (Hooking Up). It should be noted that while another film banned in New Zealand (the 2011 remake of I Spit On Your Grave) has been released in the United Kingdom classified 18 by the BBFC — the UK version of the film has had cuts made to it not made in the version submitted to the New Zealand Classification Office and is therefore excluded from the comparison.

19 Office of Film and Literature Classification Comparing Classifications 2010 & 2011 Chart 2 was derived from the following data*:

NZ UK NZ Score UK Score Count M U 3 1 1 M PG 3 2 5 M 12A 3 5 10 M 15 3 13 33 RP16 15 9 13 1 R13 15 11 13 9 R16 15 14 13 87 R16 18 14 16 8 R18 15 16 13 4 R18 18 16 16 28 BANNED 18 25 16 1

*Classifications in the table above are considered relatively consistent when they are less than or equal to 3 strength points of each other, and relatively inconsistent when they are more than 3 strength points of each other. Consistent classifications are highlighted in blue in the data table above. Overall, there are few inconsistencies between the relative strengths of New Zealand and United Kingdom classifications. In the United Kingdom age restrictions begin at 12A in cinemas, while in New Zealand they begin at R13.

The United Kingdom overall strength is higher mainly due to the number of films, 33, classified 15 there compared to M or RP16 here. It’s also due to the relative equivalency between the largest number in the sample, 87 films, respectively classified R16 in New Zealand and 15 in the United Kingdom.

In Table 4 below, of the 95 films classified R16 in New Zealand, 92% are classified 15 and the remaining 8% 18 in the United Kingdom. The relative strength of United Kingdom classifications over New Zealand is from the 87% of films carrying an age restriction of 12A or 15 compared with the New Zealand unrestricted M.

Table 4: New Zealand classifications compared to United Kingdom classifications

Number of titles = 187 Key United Kingdom Unrestricted No. of titles 1 5 10 134 37 Partial Restriction* U PG 12A 15 18 Restricted 49 M 1 5 10 33 Banned 2% 10% 20% 67% 1 RP16 1 *For theatrical release films: restricted 100% unless accompanied by a parent or 9 R13 9 guardian while viewing the film 100% 95 R16 87 8

92% 8% NewZealand 32 R18 4 28 13% 88% 1 Ban 1 100%

20 Office of Film and Literature Classification Comparing Classifications 2010 & 2011

New Zealand and the United States

Chart 3: Comparison of New Zealand and United States film classifications

Chart 3 compares the relative strength of New Zealand and United States film classifications. The chart shows:  Of the 134 films compared, over half of them were classified R16 in New Zealand and R in the United States (see the biggest bubble in the chart). While these seem equivalent at face value the strength rating for the American R is 4 points lower because of its non-restrictive nature in legal terms. Anecdotally, it is said to be widely enforced by industry at the cinema and point-of-sale.  Conversely, 18 films in the data set for comparison were classified unrestricted M in New Zealand (mostly by the New Zealand Classification Office) yet rated R in America.  It’s interesting that the American NC17+ classification, which is the only legally restrictive classification in America, does not appear at all for the titles in the data set, and was therefore not applied to the 18 films classified R18 in New Zealand. They were all rated R. These films include titles such as Drive, Saw 3D, The Human Centipede, and Harry Brown. These examples were also all rated 18 in the United Kingdom. It’s often said that film makers in the United States baulk at receiving the NC17+ rating — considered to be ‘death’ at the box office — and are known to not submit their films for classification at all if they think this will be the outcome. Classification itself is not compulsory in the United States, but almost all cinemas require films to be rated.  There was one film in the data set banned in New Zealand and rated R in America, the 2011 remake of I Spit on Your Grave.

21 Office of Film and Literature Classification Comparing Classifications 2010 & 2011 Chart 3 was derived from the following data*:

NZ USA NZ Score USA Score Count M PG 3 2 2 M PG-13 3 3 7 M R 3 10 18 RP16 R 9 10 1 R13 PG-13 11 3 1 R13 R 11 10 7 R16 PG-13 14 3 2 R16 R 14 10 77 R18 R 16 10 18 BANNED R 25 10 1

*Classifications in the table above are considered relatively consistent when they are less than or equal to 3 strength points of each other, and relatively inconsistent when they are more than 3 strength points of each other. Consistent classifications are highlighted in blue in the data table above. The surprising strength weighting difference that tips the New Zealand system closer to that of the United States is the 18 films classified M here but R in America. It may be that, for example, ‘strong sexuality and nudity’ in the US note for the film Coco Chanel and Igor Stravinsky and ‘strong sexual content’ in the US note for Sex and the City 2 indicate that sexual content is assessed differently, possibly for cultural reasons.

In Table 5 below, the most striking result is the use of the R classification in the United States where 91% of titles were rated R. Compare this with the spread of classifications used in New Zealand.

Table 5: New Zealand classifications compared to United States classifications

Number of titles = 134 Key USA Unrestricted No. of titles 2 10 122 Partial Restriction* PG PG-13 R Restricted 27 M 2 7 18 Banned 7% 26% 67% 1 RP16 1 *For theatrical release films: restricted unless 100% accompanied by a parent or guardian while 8 R13 1 7 viewing the film 13% 88% 79 R16 2 77

3% 97% NewZealand 18 R18 18 100% 1 Ban 1 100%

22 Office of Film and Literature Classification Comparing Classifications 2010 & 2011 New Zealand and Ontario

Chart 4: Comparison of New Zealand and Ontario film classifications

Chart 4 compares the relative strength of New Zealand and Ontario film classifications. The chart shows:

 Of the 180 films compared, 70 of the 98 films classified R16 in New Zealand received a 14A classification in Ontario that means ‘persons under 14 must be accompanied by an adult’. In strength terms, we consider 14A half as strong as the New Zealand R16.  Overall, along with Australia, Ontario has the least restrictive system of the countries compared.  The film banned in New Zealand was, once again, the 2011 remake of I Spit on Your Grave. Its Ontario 18A classification means that ‘Persons under 18 may attend but must be accompanied by an adult’. In this analysis 18A has a strength rating of 11.  Just three films in the sample were age restricted in Ontario. All three are classified equivalently at R18 in New Zealand.

23 Office of Film and Literature Classification Comparing Classifications 2010 & 2011 Chart 4 was derived from the following data*:

NZ Ontario NZ Score Ont Score Count M G 3 1 2 M PG 3 2 14 M 14A 3 7 25 M 18A 3 11 5 RP16 14A 9 7 1 R13 PG 11 2 1 R13 14A 11 7 8 R16 PG 14 2 4 R16 14A 14 7 70 R16 18A 14 11 24 R18 14A 16 7 6 R18 18A 16 11 16 R18 R 16 16 3 BANNED 18A 25 11 1

*Classifications in the table above are considered relatively consistent when they are less than or equal to 3 strength points of each other, and relatively inconsistent when they are more than 3 strength points of each other. Consistent classifications are highlighted in blue in the data table above. The New Zealand system is much more restrictive than Ontario’s. 136 of the 180 films compared between the two countries had lower classifications in Ontario than in New Zealand.

In Table 6 below, the most obvious point is that only 3 (less than 2% of the films in the sample) are fully age-restricted in Ontario. By this analysis, Ontario’s is the most liberal system in the comparison group, mostly due to the high use of their 14A classification.

Table 6: New Zealand classifications compared to Ontario classifications

Number of titles = 180 Key Ontario Unrestricted No. of titles 2 19 110 46 3 Partial Restriction* G PG 14A 18A R Restricted 46 M 2 14 25 5 Banned 4% 30% 54% 11% 1 RP16 1 *For theatrical release films: restricted unless accompanied by a parent or 100% guardian while viewing the film 9 R13 1 8 For films on video (DVD/Blu-ray): restricted 11% 89% unless accompanied by a parent or 98 R16 4 70 24 guardian at point of sale

4% 71% 24% NewZealand 25 R18 6 16 3 24% 64% 12% 1 Ban 1 100%

24 Office of Film and Literature Classification Comparing Classifications 2010 & 2011 New Zealand and Singapore

Chart 5: Comparison of New Zealand and Singapore film classifications

Chart 5 compares the relative strength of New Zealand and Singaporean film classifications. The chart shows:

 Of the 134 films compared, 98 (73%) are classified relatively consistently between the two countries, as shown in the chart by the large clustering of classifications along the equality line.  One film, Little Big Soldier, is R13 in New Zealand, but PG in Singapore. Little Big Soldier is a Jackie Chan produced film and was restricted in New Zealand due to the way in which the film deals with violence.  The relative strength of the Singaporean system compared to New Zealand’s is shown in the cluster of films receiving an M here, but classified NC16, M18 or R21 in Singapore. Many of the films in this group contain sexual references and other material of a sexual nature that may be less acceptable within the Singaporean cultural context.

25 Office of Film and Literature Classification Comparing Classifications 2010 & 2011 Chart 5 was derived from the following data*:

NZ Sing NZ Score Sing Score Count M PG 3 2 6 M PG13 3 3 3 M NC16 3 14 8 M M18 3 16 7 M R21 3 19 5 RP16 NC16 9 14 1 R13 PG 11 2 1 R13 NC16 11 14 3 R13 M18 11 16 3 R16 NC16 14 14 28 R16 M18 14 16 38 R16 R21 14 19 11 R18 M18 16 16 8 R18 R21 16 19 12

*Classifications in the table above are considered relatively consistent when they are less than or equal to 3 strength points of each other, and relatively inconsistent when they are more than 3 strength points of each other. Consistent classifications are highlighted in blue in the data table above. Singapore’s system is much more restrictive than New Zealand’s where unrestricted level films are concerned, but relatively comparable where legal restrictions are imposed. Singapore’s R21 classification (a classification used historically in New Zealand but repealed by our 1993 legislation) also strengthens the Singaporean system. Table 7 below illustrates that of the films classified M in New Zealand, the same films have been classified in Singapore through the range available from PG to R21. The group of films classified R21 in Singapore, but M in New Zealand all deal with themes of sex and sexuality, particularly homosexuality which is reported to be widely disapproved of in Singapore.2 Table 7: New Zealand classifications compared to Singapore classifications

Number of titles = 134 Key Singapore Unrestricted No. of titles 7 3 40 56 28 PG PG13 NC16 M18 R21 Partial Restriction* 29 M 6 3 8 7 5 Restricted 21% 10% 28% 24% 17% 1 RP16 1 *For theatrical release films: restricted 100% unless accompanied by a parent or 7 R13 1 3 3 guardian while viewing the film 14% 43% 43%

77 R16 28 38 11 NewZealand 36% 49% 14% 20 R18 8 12 40% 60%

2 Source: http://yawningbread.wordpress.com/2013/01/11/singapore-creeps-towards-more-acceptance-of-gay- people/ accessed February 2013

26 Office of Film and Literature Classification Comparing Classifications 2010 & 2011 Summary – comparing films

Overall comparison of the strength of film classification systems in the sample in 2010 and 2011

Of the 228 films included in the analysis, 99 were classified in all jurisdictions. The comparative strengths of the classification systems in terms of restrictiveness are illustrated in Chart 6.

Chart 6: Comparison of strength score averages for films – all jurisdictions

Chart 7 below summarises the relative strength of the New Zealand system compared with each of the other systems by the titles compared.

Chart 7: Average of film scores 2010 and 2011 compared to New Zealand

27 Office of Film and Literature Classification Comparing Classifications 2010 & 2011 Game Results

The following charts and tables show New Zealand game classifications compared to Australia, the United States, Ontario, PEGI [the pan-European game classification system] and Singapore. See Appendix A for details about the classification systems used.

128 titles with New Zealand classifications ranging from ‘M’ to ‘R18’ made up the data set for comparison. 115 of the games in the data set were classified in all jurisdictions. G and PG classifications were excluded as largely irrelevant to the work of the New Zealand Classification Office whose job is to deal with material that may need restriction in order to prevent injury to the public good.

The sample of eight New Zealand M classifications used in the comparisons were all assigned by the Office of Film and Literature Classification applying New Zealand classification criteria and principles. Note that under Section 8 of the Films, Videos, and Publications Classification Act 1993, games do not need to be classified and labelled unless they are likely to have content that would be restricted under the classification criteria in the Act. In practice this means that most distributors do not submit games for classification unless they have received a restricted or Teen/Adult classification in another jurisdiction.

See Appendix B for the games data set.

28 Office of Film and Literature Classification Comparing Classifications 2010 & 2011 New Zealand and Australia – games

Chart 8: Comparison of New Zealand and Australian game classifications

Chart 8 compares the relative strength of New Zealand and Australian game classifications. The chart shows:

 The strength of New Zealand game classifications over Australia’s is demonstrated by the clustering of bubbles above the equality line.  Without the option of an R18 classification for games during the period, Australia banned Mortal Kombat and Syndicate. Both were classified R18 in New Zealand. Recently, version of these games have been classified R18 in Australia.  Among other outliers, five games classified unrestricted M in New Zealand were partially restricted (MA15+) in Australia.  Just 14% of the games in the comparison are classified relatively consistently between the two countries (R13 in New Zealand compared with MA15+ in Australia). Some of this inconsistency may be due to the absence of an R18 classification for games in Australia during the period.

29 Office of Film and Literature Classification Comparing Classifications 2010 & 2011 Chart 8 was derived from the following data*:

NZ ACB NZ ACB Count M M 3 3 2 M MA15+ 3 8 5 M PG 3 2 1 R13 M 11 3 4 R13 MA15+ 11 8 18 R16 M 14 3 4 R16 MA15+ 14 8 64 R18 MA15+ 16 8 28 R18 RC 16 25 2

*Classifications in the table above are considered relatively consistent when they are less than or equal to 3 strength points of each other, and relatively inconsistent when they are more than 3 strength points of each other. Consistent classifications are highlighted in blue in the data table above. The New Zealand game classification system is more restrictive than Australia’s during the period under comparison. This finding is moderated by anecdotal knowledge and research that indicates that a large number of underage people play adult-rated games in spite of the respective systems of age restrictions in New Zealand, and parental guidance in Australia.

Table 8 shows that New Zealand makes frequent use of its R18 option for classifying games, all but two of which have the MA15+ classification in Australia. Other than outright banning, no other restriction was available for games in Australia during the period. They have since introduced an R18 for games.

Although it’s a small subset of the total sample, the majority of games classified M in New Zealand were classified MA15+ in Australia.

Almost all of the games classified R16 in New Zealand (93%) were classified MA15+ in Australia. As neither system is thought to be closely adhered to in the home, the assessment of the age safety level of these 64 games could be considered equivalent between the two countries.

Table 8: New Zealand classifications compared to Australian classifications

Number of titles = 128 Key Australia Unrestricted No. of titles 1 10 115 2 Partial Restriction* PG M MA15+ RC Restricted 8 M 1 2 5 Banned 13% 25% 63% 22 R13 4 18 * For videogames: restricted unless 18% 82% accompanied by a parent or guardian at point of sale 68 R16 4 64

NewZealand 6% 94% 30 R18 28 2 93% 7%

30 Office of Film and Literature Classification Comparing Classifications 2010 & 2011 New Zealand and United States – games

Chart 9: Comparison of New Zealand and United States game classifications

Chart 9 compares the relative strength of New Zealand and United States game classifications. The chart shows:

 A similar picture emerges to the comparison with Australia, where most games have stronger New Zealand scores illustrated by the cluster above the equality line.  The closest large cluster to the equality line is a group of 17 games classified R13 in New Zealand and M17+ in the US.  The only classifications that have equivalent strength between the two systems are the New Zealand M and the United States Teen classification.  Of the 19 ‘Teen’ games in the sample, 15 were restricted in New Zealand.

31 Office of Film and Literature Classification Comparing Classifications 2010 & 2011 Chart 9 was derived from the following data*:

NZ ESRB NZ ESRB Count M M17+ 3 9 4 M T 3 3 4 R13 M17+ 11 9 17 R13 T 11 3 5 R16 M17+ 14 9 58 R16 T 14 3 10 R18 M17+ 16 9 30

*Classifications in the table above are considered relatively consistent when they are less than or equal to 3 strength points of each other, and relatively inconsistent when they are more than 3 strength points of each other. Consistent classifications are highlighted in blue in the data table above. The American system is much less restrictive than New Zealand’s. There are only two relatively consistent groups in the table above. While ESRB has an AO classification which is enforced at the point-of-sale, and therefore equivalent in strength to the New Zealand R18, it is rarely applied.

From a search of the ESRB database, it appears that the AO rating has only been applied 36 times in the past, and often accompanied by the content descriptor ‘strong sexual content’.

Table 9 below illustrates that around a third of the titles compared between the two jurisdictions were classified R18 in New Zealand but only partially restricted in the United States.

Classifications are more finely graded in New Zealand where four different possible classifications were used for 109 of the titles in the data set, compared to a single option of M17+ used in the United States.

A curiosity is that of the 22 games restricted as R13 in New Zealand, 77% are rated M17+ for United States players. (See Appendix B for lists of titles in this category).

Table 9: New Zealand classifications compared to United States classifications

Number of titles = 128 Key ESRB (USA) Unrestricted No. of titles 19 109 Partial Restriction* Teen M17+ Restricted 8 M 4 4 50% 50% * For videogames: restricted unless accompanied by a parent or guardian at 22 R13 5 17 point of sale 23% 77%

68 R16 10 58

15% 85% NewZealand 30 R18 30 100%

32 Office of Film and Literature Classification Comparing Classifications 2010 & 2011 New Zealand and Ontario - games

Chart 10: Comparison of New Zealand and Ontario game classifications

Chart 10 compares the relative strength of New Zealand and Ontario game classifications. The chart shows:

 A very different picture emerges here from the comparison with ESRB ratings in the United States where the M17+ category is advisory only and scored 9. In Ontario, M17+ is legally enforced and scored 15 in this analysis.  New Zealand and Ontario have systems of mostly equivalent strength as demonstrated by the large cluster of bubbles on the equality line.  As in the comparison with the United States, 19 Teen games have much higher strength scores in New Zealand where most are classified R13 or R16.  The four games restricted in Ontario but unrestricted in New Zealand in the sample are: Army Corps of Hell, Catherine, Ignition and Dragon’s Dogma.  The restrictive nature of the Ontario game classification system contrasts with the film system which is considerably less restrictive than New Zealand’s.

33 Office of Film and Literature Classification Comparing Classifications 2010 & 2011 Chart 10 was derived from the following data*:

NZ ESRB (Ont) NZ ESRB (Ont) Count M M17+ 3 15 4 M T 3 3 4 R13 M17+ 11 15 17 R13 T 11 3 5 R16 M17+ 14 15 58 R16 T 14 3 10 R18 M17+ 16 15 30

*Classifications in the table above are considered relatively consistent when they are less than or equal to 3 strength points of each other, and relatively inconsistent when they are more than 3 strength points of each other. Consistent classifications are highlighted in blue in the data table above. The ESRB games classification system in Ontario is on a par with New Zealand’s because the majority of classifications in the data set are enforced in both jurisdictions. 71% of the games are classified relatively consistently.

Table 10 below illustrates that while many of the same games are restricted in both jurisdictions, the New Zealand system is more finely graded with a range of age restrictions from R13 to R18. In Ontario, 13 year-olds cannot buy 17 of the games their New Zealand counterparts can, and 16 year-olds cannot buy 58 games that their New Zealand counterparts can.

Table 10: New Zealand classifications compared to Ontario classifications

Number of titles = 128 Key ESRB (Ontario) Unrestricted No. of titles 19 109 Restricted Teen M17+ 8 M 4 4 50% 50% 22 R13 5 17 23% 77% 68 R16 10 58

15% 85% NewZealand 30 R18 30 100%

34 Office of Film and Literature Classification Comparing Classifications 2010 & 2011 New Zealand and pan-Europe - games

Chart 11: Comparison of New Zealand and PEGI game classifications

Chart 11 compares the relative strength of New Zealand and PEGI game classifications. The chart shows:

 New Zealand’s system of legally restricted classifications is considerably stronger than the advisory-only PEGI system.

 If PEGI’s system was enforced, as it is in United Kingdom from the beginning of 2013, then the largest bubble in the chart (42 games classified R16 in New Zealand but ‘18’ by PEGI) would sit on the PEGI side of the equality line with a strength score of 16.

 The only equivalently strong classifications are for the games Army Corps of Hell and El Shaddai: Ascension of the Metatron respectively classified M in New Zealand and rated ‘12’ by PEGI.

 There is a small group of games assessed as M under the New Zealand criteria that PEGI have rated ‘18’. They are Catherine, Dead Space Ignition, and Dragon’s Dogma. Curiously, these three were restricted at M17+ in , and a more in-depth investigation of the differences might be made.

35 Office of Film and Literature Classification Comparing Classifications 2010 & 2011 Chart 11 was derived from the following data*:

NZ PEGI NZ PEGI Count M 12 3 3 2 M 16 3 4 3 M 18 3 6 3 R13 12 11 3 1 R13 16 11 4 8 R13 18 11 6 13 R16 16 14 4 26 R16 18 14 6 42 R18 18 16 6 30

*Classifications in the table above are considered relatively consistent when they are less than or equal to 3 strength points of each other, and relatively inconsistent when they are more than 3 strength points of each other. Consistent classifications are highlighted in blue in the data table above. Where it is not enforced, but treated as advisory only, the PEGI system is much less restrictive than New Zealand’s. The decision whether to enforce PEGI ratings at point-of-sale is made at government level. For example, in the United Kindgom, which switched to the PEGI system in 2013, the ratings will be enforced at point-of-sale for 12, 16 and 18. In Ireland, anything receiving a PEGI 18 is assessed by the Irish Film Classification Office (IFCO) against Irish classification criteria, and may be banned or released with a restricted classification of 18. Otherwise, in Ireland, videogames are exempt from classification, but the country does support the PEGI system. Germany is notable for remaining outside the PEGI system entirely. Table 11 below illustrates that PEGI liberally use the 18 advisory classification — 68% of the sample is rated 18 (PEGI) while in New Zealand only 23% of the sample is age restricted to 18. The PEGI ratings system is administered by industry members for their own product, with training and oversight from the PEGI administration office, NICAM (the Netherlands government media regulator) and the VSC (Video Standards Council) in the United Kingdom.3 Find out more about the system at www..info Table 11: New Zealand classifications compared to PEGI classifications

Number of titles = 128 Key PEGI Unrestricted No. of titles 3 37 88 12 16 18 Restricted 8 M 2 3 3 25% 38% 38% 22 R13 1 8 13 5% 36% 59% 68 R16 26 42

NewZealand 38% 62% 30 R18 30 100%

3 It [the VSC] acts as an administrator of the PEGI system of age rating for video games. PEGI is used in over 30 countries. It [the VSC] is the UK regulator responsible for the age rating of video games supplied in the UK (using the PEGI system). In fulfilling this role it uses the name Games Rating Authority (GRA). Source: http://www.videostandards.org.uk/VSC/ accessed on 22/2/2013

36 Office of Film and Literature Classification Comparing Classifications 2010 & 2011 New Zealand and Singapore - games

Chart 12: Comparison of New Zealand and Singapore game classifications

Chart 12 compares the relative strength of New Zealand and Singapore game classifications. The chart shows:

 New Zealand’s system of legally enforceable classifications is stronger than Singapore’s system which is advisory, except for its M18 classification, which has an equivalent strength score to New Zealand’s R18.

 A large group of games in the sample for comparison – 67 out of 115 – are classified M18 in Singapore. Most of these games are also restricted in New Zealand.

 Singapore has applied an advisory classification ‘suitable for 16 and above’ with a strength score of 4 to 26 games in the data set that are restricted in New Zealand. Only 1 game in this group was classified R18.

 A group of 17 games restricted in New Zealand has been approved for distribution in Singapore. They do not need to carry a Singapore label but can carry another jurisdiction’s, such as ESRB.

 In this comparison, the game Dragon’s Dogma is an outlier scoring 16 in Singapore with an M18 classification, but 3 in New Zealand where it is rated M.

 Conversly, the game Just Cause 2 has an R18 in New Zealand but is simply approved for distribution in Singapore. The approved for distribution ‘General’ label is not seen by the MDA as an endorsement of a game’s suitability for children, rather, it simply means that the game has been approved for distribution, and it is likely that it will be carrying a label from another jurisdiction such as the United States’ ESRB system.

37 Office of Film and Literature Classification Comparing Classifications 2010 & 2011 Chart 12 was derived from the following data*:

NZ MDA NZ MDA Count M Approved 3 1 3 M M18 3 16 1 M Suitable for 16 and above 3 4 2 R13 Approved 11 1 6 R13 M18 11 16 7 R13 Suitable for 16 and above 11 4 6 R16 Approved 14 1 10 R16 M18 14 16 33 R16 Suitable for 16 and above 14 4 19 R18 Approved 16 1 1 R18 M18 16 16 26 R18 Suitable for 16 and above 16 4 1

*Classifications in the table above are considered relatively consistent when they are less than or equal to 3 strength points of each other, and relatively inconsistent when they are more than 3 strength points of each other. Consistent classifications are highlighted in blue in the data table above. The Singaporean system is less restrictive than New Zealand’s in spite of 67 M18 restricted titles, compared to 28 at R18 in New Zealand. This situation could be skewed by the high number of games in the sample merely approved for distribution. The basis for the MDA’s decision whether to classify particular games is unclear at the time of writing.

Table 12 below illustrates that of the 62 games classified as R16 in New Zealand, half are restricted to 18 years and over in Singapore, while the other half are distributed without a Singapore label or at the advisory 16 level.

Table 12: New Zealand classifications compared to Singapore classifications

Number of titles = 115 Key MDA Unrestricted No. of titles 20 28 67 Restricted Approved ADV16 M18 6 M 3 2 1 50% 33% 17% 19 R13 6 6 7 32% 32% 37% 62 R16 10 19 33

16% 31% 53% NewZealand 28 R18 1 1 26 4% 4% 93%

38 Office of Film and Literature Classification Comparing Classifications 2010 & 2011 Summary – comparing games

Overall comparison of the strength of game classification systems in the sample in 2010 and 2011

Of the 128 games in the full data set, 115 could be cross-referenced in all jurisdictions. In this comparison of strength score averages, Singapore could be said to hold the middle ground. New Zealand and Ontario’s level of restrictions are similar, as are the USA’s and Australia’s. The PEGI pan-Europe advisory only system is, understandably, the weakest in the comparison group.

Chart 13: Comparison of strength score averages for games

Chart 14 summarises the relative strength of the New Zealand system where the New Zealand classification criteria is applied to a game classification, compared with other jurisdictions. Bear in mind that the titles in the data set were submitted for classification because they received the MA15+ classification in Australia or because there was a concern by the distributor, a member of the public, or an enforcement agency that the game’s content required assessment under New Zealand’s classification criteria.

Chart 14: Average of game scores 2010 and 2011

39 Office of Film and Literature Classification Comparing Classifications 2010 & 2011 Comparisons of strength averages between 2008/09 data sets and 2010/11 data sets

Chart 13: Comparison over time of average of film classification strength scores

Chart 14: Comparison over time of average of game classification strength scores

See Appendix C for 2008/2009 strength score tables.

40 Office of Film and Literature Classification Comparing Classifications 2010 & 2011 Appendix A: Guide to Classification and Ratings Systems for Films and Games

Entertainment Software Ratings Board [games rating system used in the US and Ontario]

The Entertainment Software Rating Board (ESRB) is a non-profit, self-regulatory body that assigns age and content ratings for video games and mobile apps so parents can make informed choices. As part of its self-regulatory role for the video game industry the ESRB also enforces industry-adopted advertising guidelines and helps ensure responsible online privacy practices under its Privacy Online program. ESRB was established in 1994 by the Entertainment Software Association (ESA).4

EARLY CHILDHOOD Titles rated EC (Early Childhood) have content that may be suitable for ages 3 and older. Contains no material that parents would find inappropriate.

EVERYONE Titles rated E (Everyone) have content that may be suitable for ages 6 and older. Titles in this category may contain minimal cartoon, fantasy or mild violence and/or infrequent use of mild language.

EVERYONE 10+ Titles rated E10+ (Everyone 10 and older) have content that may be suitable for ages 10 and older. Titles in this category may contain more cartoon, fantasy or mild violence, mild language and/or minimal suggestive themes.

TEEN Titles rated T (Teen) have content that may be suitable for ages 13 and older. Titles in this category may contain violence, suggestive themes, crude humor, minimal blood, simulated gambling, and/or infrequent use of strong language.

MATURE [enforced in Ontario] Titles rated M (Mature) have content that may be suitable for persons ages 17 and older. Titles in this category may contain intense violence, blood and gore, sexual content and/or strong language.

ADULTS ONLY [enforced in Ontario and the United States] Titles rated AO (Adults Only) have content that should only be played by persons 18 years and older. Titles in this category may include prolonged scenes of intense violence and/or graphic sexual content and nudity.

4 http://www.esrb.org/about/index.jsp

41 Office of Film and Literature Classification Comparing Classifications 2010 & 2011 Pan-European Game Information (PEGI) [games]

The Pan-European Game Information (PEGI) age rating system was established to help European parents make informed decisions on buying computer games. It was launched in spring 2003 and replaced a number of national age rating systems with a single system now used throughout most of Europe, in 30 countries (Austria Denmark, Hungary, Latvia, , Slovenia, Belgium, Estonia, Iceland, Lithuania, Poland, Spain, Bulgaria, Finland, Ireland, Luxembourg, Portugal, Sweden, Cyprus, France, Israel, Malta, Romania, Switzerland, Czech Republic, Greece, Italy, the Netherlands, Slovak Republic and the United Kingdom). The system is supported by the major console manufacturers, including , Microsoft and , as well as by publishers and developers of interactive games throughout Europe. The age rating system was developed by the Interactive Software Federation of Europe (ISFE).5

PEGI 3 The content of games given this rating is considered suitable for all age groups. Some violence in a comical context (typically Bugs Bunny or Tom & Jerry cartoon-like forms of violence) is acceptable. The child should not be able to associate the character on the screen with real life characters, they should be totally fantasy. The game should not contain any sounds or pictures that are likely to scare or frighten young children. No bad language should be heard.

PEGI 7 Any game that would normally be rated at 3 but contains some possibly frightening scenes or sounds may be considered suitable in this category.

PEGI 12 Videogames that show violence of a slightly more graphic nature towards fantasy character and/or non graphic violence towards human-looking characters or recognisable animals, as well as videogames that show nudity of a slightly more graphic nature would fall in this age category. Any bad language in this category must be mild and fall short of sexual expletives.

PEGI 16 This rating is applied once the depiction of violence (or sexual activity) reaches a stage that looks the same as would be expected in real life. More extreme bad language, the concept of the use of tobacco and drugs and the depiction of criminal activities can be content of games that are rated 16.

PEGI 18 The adult classification is applied when the level of violence reaches a stage where it becomes a depiction of gross violence and/or includes elements of specific types of violence. Gross violence is the most difficult to define since it can be very subjective in many cases, but in general terms it can be classed as the depictions of violence that would make the viewer feel a sense of revulsion.

5 http://www.pegi.info/en/index/id/28/

42 Office of Film and Literature Classification Comparing Classifications 2010 & 2011

PEGI content symbols6 Descriptors shown on the back of the packaging indicate the main reasons why a game has received a particular age rating. There are eight such descriptors: violence, bad language, fear, drugs, sexual, discrimination, gambling and online gameplay with other people.

Bad Language Game contains bad language

Discrimination Game contains depictions of, or material which may encourage, discrimination

Drugs Game refers to or depicts the use of drugs

Fear Game may be frightening or scary for young children

Gambling Games that encourage or teach gambling

Sex Game depicts nudity and/or sexual behaviour or sexual references

Violence Game contains depictions of violence

Online gameplay Game can be played online

6 http://www.pegi.info/en/index/id/33/

43 Office of Film and Literature Classification Comparing Classifications 2010 & 2011 British Board of Film Classification (BBFC) [films]

The British Board of Film Censors was set up in 1912 by the film industry as an independent body to bring a degree of uniformity to the classification of film nationally. Statutory powers on film remain with the local councils, which may overrule any of the BBFC’s decisions, passing films we reject, banning films we have passed, and even waiving cuts, instituting new ones, or altering categories for films exhibited under their own licensing jurisdiction. Video – In 1984 Parliament passed the Video Recordings Act. This act stated that, subject to certain exemptions, video recordings offered for sale or hire commercially in the UK must be classified by an authority designated by the Secretary of State. The President and Vice Presidents of the BBFC were so designated, and charged with applying the new test of ‘suitability for viewing in the home’. At this point the Board’s title was changed to the British Board of Film Classification to reflect the fact that classification plays a far larger part in the BBFC’s work than censorship.7

Suitable for all It is impossible to predict what might upset any particular child. But a ‘U’ film should be suitable for audiences aged four years and over. ‘U’ films should be set within a positive moral framework and should offer reassuring counterbalances to any violence, threat or horror. If a work is particularly suitable for a pre-school child to view alone, this will be indicated in the Consumer Advice.

Parental Guidance General viewing, but some scenes may be unsuitable for young children. Unaccompanied children of any age may watch. A ‘PG’ film should not disturb a child aged around eight or older. However, parents are advised to consider whether the content may upset younger or more sensitive children.

Suitable for 12 years and over Exactly the same criteria are used to classify works at ‘12A’ and ‘12’. These categories are awarded where the material is suitable, in general, only for those aged 12 and over. Works classified at these categories may upset children under 12 or contain material which many parents will find unsuitable for them. The ‘12A’ category exists only for cinema films. No one younger than 12 may see a ‘12A’ film in a cinema unless accompanied by an adult, and films classified ‘12A’ are not recommended for a child below 12. The ‘12’ category exists only for video works. No one younger than 12 may rent or buy a ‘12’ rated video work.

Suitable only for 15 years or over No-one younger than 15 may see a ‘15’ film in a cinema. No-one younger than 15 may rent or buy a ‘15’ rated video work.

Suitable only for adults No-one younger than 18 may see an ‘18’ film in a cinema. No- one younger than 18 may rent or buy an ‘18’ rated video work.

To be shown only in specially licensed cinemas, or supplied only in licensed sex shops, and to adults of not less than 18 years. The ‘R18’ category is a special and legally restricted classification primarily for explicit works of consenting sex or strong fetish material involving adults. Films may only be shown to adults in specially licensed cinemas, and video works may be supplied to adults only in licensed sex shops.

7 http://www.bbfc.org.uk/about/

44 Office of Film and Literature Classification Comparing Classifications 2010 & 2011 Motion Picture Association of America (rating system known as CARA) [films]

The MPAA partnered with the National Association of Theater Owners (NATO) which supports and enforces the system by requiring identification when needed and refusing admission to R-rated movies by unaccompanied children or to NC-17 rated movies by children under 18. Today NATO's members include the largest cinema chains in the country and hundreds of independent theatre owners, representing more than 29,000 movie screens across the country. It is this participation that completes the service the rating system provides to parents.8

THE MOTION PICTURE CONTAINS NOTHING THAT WOULD OFFEND PARENTS FOR VIEWING BY THEIR CHILDREN.

PARENTS ARE URGED TO USE "PARENTAL GUIDANCE", AS THE MOTION PICTURE MAY CONTAIN SOME MATERIAL PARENTS MIGHT NOT LIKE FOR THEIR YOUNGER CHILDREN TO VIEW.

PARENTS ARE URGED TO BE CAUTIOUS. SOME MATERIAL MAY BE INAPPROPRIATE FOR PRE-TEENAGERS.

CONTAINS SOME ADULT MATERIAL. PARENTS ARE URGED TO LEARN MORE ABOUT THE MOTION PICTURE BEFORE TAKING THEIR YOUNGER CHILDREN WITH THEM.

GENERALLY, IT IS NOT APPROPRIATE FOR PARENTS TO BRING THEIR YOUNG CHILDREN WITH THEM TO R-RATED MOTION PICTURES.

PATENTLY ADULT. CHILDREN ARE NOT ADMITTED.

8 http://www.filmratings.com/filmRatings_Cara/#/about/ourPartners/

45 Office of Film and Literature Classification Comparing Classifications 2010 & 2011 Ontario Film Review Board [films]

The Ontario Film Review Board (OFRB) receives its mandate through the Film Classification Act, 2005 and operates as an arms-length agency reporting to the Minister of Consumer Services. Subject to certain exceptions, if a film (e.g. movie, video, DVD, VCD or video game) is to be distributed or screened in Ontario, it must first be classified by our Board. Our objective is to classify film and thereby provide the public with sufficient information to make informed viewing choices for themselves and for their children.9

Suitable for viewers of all ages.

Parental guidance is advised. Theme or content may not be suitable for all children.

Suitable for viewing by persons 14 years of age and older. Persons under 14 must be accompanied by an adult. May contain: violence, coarse language and/or sexually suggestive scenes.

Suitable for viewing by persons 18 years of age and older. Persons under 18 may attend but must be accompanied by an adult. May contain: explicit violence, frequent coarse language, sexual activity and/or horror.

Admittance restricted to persons 18 years of age and over. Content not suitable for minors. May contain: frequent use of sexual activity, brutal/graphic violence, intense horror and/or other disturbing content.

9 http://www.ofrb.gov.on.ca/english/page2.htm

46 Office of Film and Literature Classification Comparing Classifications 2010 & 2011 Singapore Media Development Authority [films] Film ratings are accompanied with consumer advice and classification information. Consumers, especially parents, can use the classification information when deciding an appropriate movie for their children or younger audiences. Videos distributed in Singapore are classified up to the M18 rating while films meant for theatrical release are classified up to the R21 rating.10

Films in Singapore are rated according to the following categories:

General Suitable for all ages.

Parental Guidance Suitable for all, but parents should guide their young.

Parental Guidance 13 Suitable for persons aged 13 and above but parental guidance is advised for children below

13.

No Children Under 16

Suitable for persons aged 16 and above.

Mature 18

Suitable for persons aged 18 and above.

Restricted 21

Restricted to persons aged 21 and above

The Video Games Classification system instituted in 2008 is made up of the Age Advisory (Suitable for 16 and Above) and M18 ratings. Titles that are rated General need not carry any rating stickers. [General means that the game has been approved for distribution.]

1. Mature 18 (M18) – For persons 18 years old and above. M18 is a restricted category and retailers will need to conduct age checks at the point of sale.

2. Age Advisory – Suitable for persons 16 years old and above. This is an advisory category to assist consumers in making informed choices. While retailers need not conduct age checks at the point of sale, they are encouraged to exercise responsibility by not selling these games to those below 16 years of age. Both categories will carry rating stickers. Games that do not fall into the above two categories but are approved for general consumption are not required to carry any rating stickers.11

10 https://app.mda.gov.sg/Classification/Search/Film/ 11 http://www.mda.gov.sg/NEWSANDEVENTS/PRESSRELEASE/2008/Pages/14042008.aspx

47 Office of Film and Literature Classification Comparing Classifications 2010 & 2011 Australian Classification Board [films and games]

Every film and computer game has to be classified before it can be legally made available to the public. Some publications also need to be classified. There are limited exceptions to this rule. In addition to commercial material, the Classification Board also classifies material submitted from the police, the Australian Customs and Border Protection Service and the Australian Communications and Media Authority (ACMA). The Board classifies internet sites referred by ACMA and video content developed by for distribution over mobile phone networks. The Board also provides classifications to the Australian Customs and Border Protection Service in relation to the importation of publications, videos and computer games. The Board does not classify TV programs or films for broadcast on TV.12

G – General There are no legal restrictions on the sale, hire or screening of films classified G.

PG – Parental guidance recommended There are no legal restrictions on the sale, hire or screening of films classified PG. It should be remembered however, that films classified PG are not recommended for people under 15 without guidance from a parent or guardian.

M – Recommended for mature audiences There are no legal restrictions on the sale, hire or screening of films classified M. It should be remembered however, that films classified M are not recommended for people under 15 years as these contain content that is recommended for a mature audience.

MA15+ In all States and Territories (except Queensland) it is an offence to exhibit an MA15+ film if a person aged under 15 years is present and they are not accompanied by their parent or adult guardian. In Queensland, a person aged between 2 and 15 cannot be admitted to a MA15+ film unless they are accompanied by an adult. Films classified MA15+ can only be sold or hired to people aged 15 years or older, unless they are accompanied by their parent or guardian, or in Queensland by an adult.

R18+ In all States and Territories (except Queensland) a R18+ film cannot be exhibited in a public place in the presence of a person who is under 18 years. In Queensland, people aged between 2 and under 18 cannot be admitted to a R18+ film. In addition, in Tasmania a R18+ film cannot be screened if it can be seen from a public place. Films classified R18+ can only be sold or hired to adults aged 18 years and over.13

X18+ This classification applies to films that contain only sexually explicit content. Films classified X 18+ can be legally exhibited in the Australian Capital Territory and the Northern Territory provided certain conditions are met. For example, they can only be exhibited in a restricted publications area to which only people aged 18 and over are permitted to enter. Films classified X 18+ can only be sold or hired in the Australian Capital Territory and the Northern Territory provided certain conditions are met. For example, the film must be sold or hired in a restricted publications area to which only people aged 18 and over are permitted to enter.

‘RC’ = Refused Classification (banned)

12http://www.classification.gov.au/Pages/About-Us/Who-We-Are.aspx 13 Games are only classified to MA15+ during the period in this study. An R18 classification for games has been introduced from 2013.

48 Office of Film and Literature Classification Comparing Classifications 2010 & 2011 Office of Film and Literature Classification and the Film and Video Labelling Body [films and games]

All films, DVDs and restricted games must carry New Zealand classification labels before be supplied or exhibited to the public. The Film and Video Labelling Body can rate unrestricted films (G, PG or M) – this is usually done by assigning a New Zealand equivalent to the Australian or British (BBFC) classification. The Classification Office applies the classification criteria in the Films, Videos, and Publications Classification Act 1993. It is an Independent Crown Entity and has the power to classify material in a wide variety of media, including books, magazines, games, films and computer files. All restricted-level films and games must be classified by the Classification Office before being supplied or exhibited.

G – suitable for general audiences Films and games with a G label can be sold, hired, or shown to anyone.

PG – parental guidance recommended for younger viewers Films and games with a PG label can be sold, hired, or shown to anyone.

M – suitable for mature audiences 16 years and over Films and games with an M label can be sold, hired, or shown to anyone.

RP13 – restricted to persons 13 years and over unless accompanied by a parent or guardian A parent, shop or cinema is breaking the law if they allow unaccompanied children to access these films.

RP16 – restricted to persons 16 years and over unless accompanied by a parent or guardian

R13 – restricted to persons 13 years and over It is illegal to sell, hire, show or give a film or game with an age restricted label to anyone under the age specified.

R15 – restricted to persons 15 years and over

R16 – restricted to persons 16 years and over

R18 – restricted to persons 18 years and over

‘Objectionable’= banned

49 Office of Film and Literature Classification Comparing Classifications 2010 & 2011 Appendix B: Films and games used in this study

Films

Title Source NZ Aus UK USA Ontario Singapore A Film Unfinished OFLC M M R 18A A Somewhat Gentle Man LBVP M MA15+ Albert Nobbs LBVP M M 15 R 14A M18 Anton Chekhov's The Duel OFLC M PG Beeswax LBVP M M 14A Beginners OFLC M M 15 R 14A R21 Boy LBVP M M 14A NC16 Cemetery Junction OFLC M MA15+ 15 R 14A NC16 Certified Copy LBVP M M 12A PG Coco Chanel & Igor Stravinsky OFLC M MA15+ 15 R 18A R21 Elena OFLC M M 12A Endgame LBVP M M PG-13 Everyone Else LBVP M MA15+ Footloose LBVP M M 12A PG-13 PG PG13 Footnote LBVP M PG PG PG From Time to Time LBVP M PG PG PG Gainsbourg OFLC M M 15 14A Get Low LBVP M M PG PG-13 PG How I Ended This Summer LBVP M M 12A I Killed My Mother LBVP M M 15 14A Io Sono L'Amore OFLC M MA15+ 15 R 18A R21 Legend is Born - Ip Man LBVP M M 15 PG PG Love In A Puff OFLC M MA15+ Love Like Poison OFLC M M 15 Love Story OFLC M M PG Mammoth OFLC M M 15 M18 Mammuth LBVP M MA15+ 15 R21 Marwencol LBVP M M PG Melancholia OFLC M M 15 R PG M18 Most Dangerous Man in America - Daniel Ellsberg & The Pentagon Papers LBVP M PG Mother And Child OFLC M MA15+ 15 R PG M18 Mysteries of Lisbon LBVP M PG PG New York, I Love You OFLC M MA15+ 15 R 14A M18 Nothing To Declare OFLC M M 14A Of Gods and Men OFLC M MA15+ 15 PG-13 14A NC16 Once Upon A Time In Anatolia OFLC M M 15 14A Reign Of Assassins OFLC M MA15+ R Road Movie LBVP M M 15 14A NC16 The Salt of Life LBVP M PG 12A PG Sex And The City 2 OFLC M MA15+ 15 R 18A R21 She Monkeys OFLC M M 12A Silent Wedding OFLC M M Sleeping Sickness OFLC M 14A Soul Kitchen OFLC M MA15+ 18A M18 Submarine OFLC M M 15 R 14A NC16 Super 8 LBVP M M 12A PG-13 PG PG Tabloid OFLC M M 15 R 14A Take Shelter OFLC M M 15 R 14A PG13 Teenage Paparazzo LBVP M M 14A NC16 Terri LBVP M M R 14A The Forgiveness of Blood LBVP M PG 12A PG The Future LBVP M M 12A R 14A The Ghost Writer OFLC M MA15+ 15 PG-13 PG NC16 The Holy Roller LBVP M PG The Innkeepers OFLC M M 15 R 14A PG13 The Insatiable Moon LBVP M M 15 The Missing Person OFLC M M 15 The Myth Of The American Sleepover OFLC M M 15 The Orator LBVP M PG The Trip OFLC M MA15+ 14A The White Ribbon OFLC M M 15 R 14A M18 Tomboy LBVP M G U PG NC16 Troll Hunter OFLC M M 15 PG-13 PG PG

50 Office of Film and Literature Classification Comparing Classifications 2010 & 2011 Films cont/

Title Source NZ Aus UK USA Ontario Singapore TT3D: Closer To The Edge OFLC M M 15 Uncle Boonmee Who Can Recall His Past Lives OFLC M M 12A G PG Upside Down: The Creation Records Story LBVP M MA15+ 15 14A Wah Do Dem LBVP M M 15 Waste Land OFLC M M PG G PG Welcome OFLC M M 15 14A PG Wind Journeys LBVP M M Women Without Men OFLC M M 15 14A 127 Hours FLBoR RP16 MA15+ 15 R 14A NC16 Four Lions OFLC R13 M 15 R 14A M18 Fright Night OFLC R13 MA15+ 15 R 14A NC16 Lemmy OFLC R13 MA15+ 15 14A Little Big Soldier OFLC R13 M 15 PG-13 PG PG Paul OFLC R13 MA15+ 15 R 14A NC16 Restrepo OFLC R13 MA15+ 15 R 14A The Guard OFLC R13 MA15+ 15 R 14A M18 What's Your Number? OFLC R13 MA15+ 15 R 14A M18 Winter's Bone OFLC R13 MA15+ 15 R 14A NC16 13 Assassins OFLC R16 MA15+ 15 R 14A NC16 25 Kilates OFLC R16 MA15+ A Few Best Men OFLC R16 MA15+ 15 M18 A Nightmare On Elm Street OFLC R16 MA15+ 18 R 18A M18 American: The Bill Hicks Story OFLC R16 M 15 PG Animal Kingdom OFLC R16 MA15+ 15 R 14A NC16 Armadillo OFLC R16 MA15+ 15 14A M18 Attack The Block OFLC R16 MA15+ 15 R 14A M18 Attenberg OFLC R16 MA15+ 18 18A Bad Teacher OFLC R16 M 15 R 14A M18 Beyond OFLC R16 MA15+ 14A NC16 Biutiful OFLC R16 MA15+ 15 R 14A Black Swan OFLC R16 MA15+ 15 R 14A Blue Valentine OFLC R16 MA15+ 15 R 18A R21 Bridesmaids OFLC R16 MA15+ 15 R 14A M18 Brighton Rock OFLC R16 MA15+ 15 R 14A Buried OFLC R16 MA15+ 15 R 14A NC16 Cedar Rapids OFLC R16 MA15+ 15 R 14A Centurion OFLC R16 MA15+ 15 R 18A M18 Circumstance OFLC R16 MA15+ 15 R 14A Conan The Barbarian OFLC R16 MA15+ 15 R 18A R21 Cop Out OFLC R16 MA15+ 15 R 14A M18 Daybreakers OFLC R16 MA15+ R 18A M18 Due Date OFLC R16 MA15+ 15 R 14A NC16 Edge Of Darkness OFLC R16 MA15+ 15 R 14A NC16 Final Destination 5 OFLC R16 MA15+ 15 R 18A R21 Fish Tank OFLC R16 MA15+ 15 18A M18 Friends With Benefits OFLC R16 MA15+ 15 R 14A M18 From Paris With Love OFLC R16 MA15+ 15 R 14A M18 Gantz OFLC R16 MA15+ 15 14A NC16 Gantz: Perfect Answer OFLC R16 MA15+ 15 PG NC16 Get Him To The Greek OFLC R16 MA15+ 15 R 14A Goemon OFLC R16 MA15+ 15 14A NC16 Going The Distance OFLC R16 MA15+ 15 R 14A M18 Hall Pass OFLC R16 MA15+ 15 R 14A Happy, Happy OFLC R16 M 15 Headhunters OFLC R16 MA15+ 15 R 14A M18 Horrible Bosses OFLC R16 MA15+ 15 R 14A M18 Hot Tub Time Machine OFLC R16 MA15+ 15 R 18A M18 I Love You, Phillip Morris OFLC R16 MA15+ 15 R 14A I'm Still Here OFLC R16 MA15+ 15 R 14A Immortals OFLC R16 MA15+ R 18A M18 In A Better World OFLC R16 MA15+ 15 R 14A NC16 3D OFLC R16 MA15+ 18 R 18A R21 Killer Elite OFLC R16 MA15+ 15 R 14A M18

51 Office of Film and Literature Classification Comparing Classifications 2010 & 2011 Films cont/

Title Source NZ Aus UK USA Ontario Singapore Knuckle OFLC R16 MA15+ 15 R 14A La Doppia Ora OFLC R16 M Lebanon OFLC R16 MA15+ 15 R 18A NC16 Let Me In OFLC R16 MA15+ 15 R 14A NC16 Let The Bullets Fly OFLC R16 MA15+ 15 14A Little White Lies OFLC R16 MA15+ 15 14A M18 Love And Other Drugs OFLC R16 MA15+ 15 R 14A M18 Martha Marcy May Marlene OFLC R16 MA15+ 15 R 14A M18 Michael OFLC R16 MA15+ 18 No Strings Attached OFLC R16 MA15+ 15 R 14A M18 Norwegian Wood OFLC R16 MA15+ 15 14A Paranormal Activity OFLC R16 M 15 R 14A NC16 OFLC R16 M 15 R 14A NC16 Partir OFLC R16 MA15+ 15 14A Point Blank OFLC R16 MA15+ 15 R 14A NC16 Precious: Based On The Novel Push By Sapphire OFLC R16 MA15+ 15 R 14A M18 Predators OFLC R16 MA15+ 15 R 14A NC16 Resident Evil: Afterlife OFLC R16 MA15+ 15 R 18A NC16 Rubber OFLC R16 MA15+ 15 R 14A M18 Scream 4 OFLC R16 MA15+ 15 R 14A NC16 Shaolin OFLC R16 MA15+ 15 R PG Shark Night 3D OFLC R16 M 15 PG-13 14A NC16 She's Out Of My League OFLC R16 MA15+ 15 R 14A NC16 Shifty OFLC R16 MA15+ 18A M18 Shut Up Little Man! An Audio Misadventure OFLC R16 MA15+ 14A R21 Shutter Island OFLC R16 MA15+ 15 R 14A NC16 Splice OFLC R16 MA15+ 15 R 18A R21 Stieg Larsson's The Girl Who Kicked The Hornet's Nest OFLC R16 MA15+ 15 R 14A NC16 Stieg Larsson's The Girl Who Played With Fire OFLC R16 MA15+ 15 R 18A The American OFLC R16 MA15+ 15 R 14A R21 The Bang Bang Club OFLC R16 MA15+ 15 R 14A M18 The Book Of Eli OFLC R16 MA15+ 15 R 14A NC16 The Change-Up OFLC R16 MA15+ 15 R 18A R21 The Debt OFLC R16 MA15+ 15 R 14A NC16 The Devil's Rock OFLC R16 MA15+ 18 18A M18 The Disappearance Of Alice Creed OFLC R16 MA15+ 18 R 14A The Expendables OFLC R16 MA15+ R 18A M18 The Fighter OFLC R16 MA15+ 15 R 14A M18 The Giants OFLC R16 M 15 The Hangover Part II OFLC R16 MA15+ 15 R 18A R21 The Housemaid OFLC R16 MA15+ 18 The Hurt Locker OFLC R16 MA15+ 15 R 14A M18 The Inbetweeners Movie OFLC R16 MA15+ 15 R 14A M18 The Kids Are All Right OFLC R16 MA15+ 15 R 18A R21 The Last Exorcism OFLC R16 MA15+ 15 PG-13 14A NC16 The Mill & The Cross OFLC R16 M 14A The Misfortunates OFLC R16 18A The Names Of Love OFLC R16 R 14A R21 The Reluctant Infidel OFLC R16 MA15+ 15 14A The Road OFLC R16 MA15+ 15 R 14A NC16 The Runaways OFLC R16 MA15+ 15 R 14A M18 The Thing OFLC R16 MA15+ 15 R 14A NC16 The Town OFLC R16 MA15+ 15 R 14A M18 The Warrior's Way OFLC R16 MA15+ 15 R PG M18 The Whistleblower OFLC R16 MA15+ 15 R 14A M18 The Wolfman OFLC R16 MA15+ 15 R 18A NC16 Toomelah OFLC R16 MA15+ Tucker & Dale Vs Evil OFLC R16 MA15+ 15 R 14A We Need To Talk About Kevin OFLC R16 MA15+ 15 R 14A M18 Weekend OFLC R16 MA15+ 18 When We Leave OFLC R16 MA15+ 14A M18 White Material OFLC R16 MA15+ 15 William S. Burroughs: A Man Within OFLC R16 M

52 Office of Film and Literature Classification Comparing Classifications 2010 & 2011 Films cont/

Title Source NZ Aus UK USA Ontario Singapore William S. Burroughs: A Man Within OFLC R16 M Your Highness OFLC R16 MA15+ 15 R 18A M18 3-D Sex And Zen: Extreme Ecstasy OFLC R18 R18+ R R21 Amer OFLC R18 18 M18 Ballad Of The Sad Trumpet OFLC R18 MA15+ R 18A Beauty OFLC R18 R18+ 18 Blessed OFLC R18 MA15+ 18 Bronson OFLC R18 MA15+ 18 R 14A R21 Celda 211 OFLC R18 MA15+ 18 18A M18 Drive OFLC R18 MA15+ 18 R 18A M18 Elite Squad 2 OFLC R18 MA15+ 18 18A M18 Enter The Void OFLC R18 R18+ 18 R Harry Brown OFLC R18 MA15+ 18 R 18A Hobo With A Shotgun OFLC R18 R18+ 18 R R21 I Saw The Devil OFLC R18 R18+ 18 18A R21 Kaboom OFLC R18 MA15+ 15 18A Kick-Ass OFLC R18 MA15+ 15 R 18A M18 Kill List OFLC R18 R18+ 18 Machete OFLC R18 MA15+ 18 R 18A R21 Piranha 3D OFLC R18 MA15+ 15 R 18A R21 Red State OFLC R18 MA15+ 18 R 14A M18 Saw 3D OFLC R18 R18+ 18 R 18A R21 Sleeping Beauty OFLC R18 MA15+ 18 14A R21 Snowtown OFLC R18 MA15+ 18 The Collector OFLC R18 R18+ 18 R 18A The Girl With The Dragon Tattoo OFLC R18 MA15+ 18 R 18A R21 The Human Centipede (First Sequence) OFLC R18 R18+ 18 R The Killer Inside Me OFLC R18 MA15+ 18 R 14A R21 The Man From Nowhere OFLC R18 MA15+ 18 R 14A M18 The Woman OFLC R18 R18+ 18 R The Yellow Sea OFLC R18 R18+ 18 R 18A R21 Trash Humpers OFLC R18 R18+ 18 Tyrannosaur OFLC R18 MA15+ 18 14A M18 Un Prophète OFLC R18 MA15+ 18 R 18A Viva Riva! OFLC R18 MA15+ 15 R 18A R21 Wound OFLC R18 R18+ 18 Hooking Up OFLC BANNED R18+ 18 I Spit On Your Grave OFLC BANNED R18+ R 18A Megan Is Missing OFLC BANNED MA15+ Sick Girl OFLC BANNED R18+

53 Office of Film and Literature Classification Comparing Classifications 2010 & 2011 Games

Title NZ Aus USA Canada Pan-Europe Singapore Dead or Alive: Dimensions M M T T 16 General Dead Space Ignition M M M17+ M17+ 18 n/a All Zombies Must Die! M MA15+ T T 16 n/a Army Corps Of Hell M MA15+ M17+ M17+ 12 Suitable for 16 and above Catherine M MA15+ M17+ M17+ 18 Suitable for 16 and above Dragon's Dogma M MA15+ M17+ M17+ 18 M18 Uncharted: Golden Abyss M MA15+ T T 16 General El Shaddai: Ascension Of The Metatron M PG T T 12 General 007: Quantum Of Solace R13 M T T 16 General Fighters Uncaged R13 M T T 16 General Naughty Bear R13 M T T 12 General The Conduit R13 M T T 16 General Binary Domain R13 MA15+ M17+ M17+ 18 Suitable for 16 and above Castlevania: Lords Of Shadow R13 MA15+ M17+ M17+ 16 M18 Dark Souls R13 MA15+ M17+ M17+ 16 Suitable for 16 and above Dead Nation R13 MA15+ M17+ M17+ 18 n/a Diablo III R13 MA15+ M17+ M17+ 16 Suitable for 16 and above Fable III R13 MA15+ M17+ M17+ 16 M18 Hunted: The Demon's Forge R13 MA15+ M17+ M17+ 18 Suitable for 16 and above Kingdoms Of Amalur: Reckoning R13 MA15+ M17+ M17+ 18 Suitable for 16 and above Lord Of The Rings: War In The North R13 MA15+ M17+ M17+ 18 M18 - Classics R13 MA15+ M17+ M17+ 18 n/a Mass Effect 2 R13 MA15+ M17+ M17+ 18 Suitable for 16 and above R13 MA15+ M17+ M17+ 18 M18 Metal Gear Solid: Peace Walker R13 MA15+ T T 18 General NeverDead R13 MA15+ M17+ M17+ 18 M18 The Elder Scrolls V: Skyrim R13 MA15+ M17+ M17+ 18 M18 Two Worlds II R13 MA15+ M17+ M17+ 16 General Vanquish R13 MA15+ M17+ M17+ 18 M18 Weird World R13 MA15+ M17+ M17+ 18 n/a Alan Wake R16 M T T 16 General Blood Stone 007 R16 M T T 16 General Goldeneye 007 R16 M T T 16 General The Fight R16 M T T 16 Suitable for 16 and above Alice: Madness Returns R16 MA15+ M17+ M17+ 18 Suitable for 16 and above ArmA II: Operation Arrowhead R16 MA15+ M17+ M17+ 18 M18 Assassin's Creed: Brotherhood R16 MA15+ M17+ M17+ 18 Suitable for 16 and above Assassin's Creed: Revelations R16 MA15+ M17+ M17+ 18 Suitable for 16 and above Battlefield 3 R16 MA15+ M17+ M17+ 16 Suitable for 16 and above Battlefield Bad Company 2 R16 MA15+ M17+ M17+ 16 Suitable for 16 and above BioShock 2 R16 MA15+ M17+ M17+ 18 M18 Blacklight : Tango Down R16 MA15+ T T 16 n/a Bodycount R16 MA15+ M17+ M17+ 16 Suitable for 16 and above Brink R16 MA15+ T T 16 General : Black Ops R16 MA15+ M17+ M17+ 16 M18 Call of Duty: Modern Warfare 3 R16 MA15+ M17+ M17+ 16 Suitable for 16 and above Crackdown 2 R16 MA15+ M17+ M17+ 18 Suitable for 16 and above Crysis 2 R16 MA15+ M17+ M17+ 16 M18 Dante's Inferno R16 MA15+ M17+ M17+ 18 M18 Deadliest Warrior: The Game R16 MA15+ M17+ M17+ 18 n/a Deep Black R16 MA15+ M17+ M17+ 16 n/a Deus Ex: Human Revolution R16 MA15+ M17+ M17+ 18 M18 Dragon Age II R16 MA15+ M17+ M17+ 18 M18 Dragon Age: Origins (Ultimate Edition) R16 MA15+ M17+ M17+ 18 M18 Dragon Age: Origins Awakening R16 MA15+ M17+ M17+ 18 M18 Fight Night Champion R16 MA15+ M17+ M17+ 16 M18 Fist Of The North Star: Ken's Rage R16 MA15+ M17+ M17+ 18 Suitable for 16 and above

54 Office of Film and Literature Classification Comparing Classifications 2010 & 2011 Games cont/ Title NZ Aus USA Canada Pan-Europe Singapore God Of War III R16 MA15+ M17+ M17+ 18 M18 God Of War: Ghost Of Sparta R16 MA15+ M17+ M17+ 18 M18 Halo Reach R16 MA15+ M17+ M17+ 16 General Halo: Anniversary R16 MA15+ M17+ M17+ 16 General Homefront R16 MA15+ M17+ M17+ 18 M18 Killzone 3 R16 MA15+ M17+ M17+ 18 M18 L.A. Noire R16 MA15+ M17+ M17+ 18 M18 Medal Of Honor R16 MA15+ M17+ M17+ 18 M18 Metro 2033 R16 MA15+ M17+ M17+ 16 Suitable for 16 and above Nier R16 MA15+ M17+ M17+ 18 Suitable for 16 and above No More Heroes 2 - Desperate Struggle R16 MA15+ M17+ M17+ 18 M18 Operation Flashpoint : Red River R16 MA15+ M17+ M17+ 18 M18 Rage R16 MA15+ M17+ M17+ 18 M18 Red Dead Redemption R16 MA15+ M17+ M17+ 18 M18 Red Dead Redemption : Undead Nightmare R16 MA15+ M17+ M17+ 18 M18 Red Faction: Armageddon R16 MA15+ M17+ M17+ 18 M18 Red Orchestra 2: Heroes Of Stalingrad R16 MA15+ M17+ M17+ 18 Suitable for 16 and above Resident Evil Revelations R16 MA15+ M17+ M17+ 16 Suitable for 16 and above Resident Evil: Operation Raccoon City R16 MA15+ M17+ M17+ 18 M18 Resident Evil: The Mercenarie s 3D R16 MA15+ M17+ M17+ 18 Suitable for 16 and above Resistance 3 R16 MA15+ M17+ M17+ 18 M18 Rush'N Attack: Ex-Patriot R16 MA15+ M17+ M17+ 16 n/a Shadows Of The Damned R16 MA15+ M17+ M17+ 18 M18 Shank R16 MA15+ M17+ M17+ 18 n/a Shank 2 R16 MA15+ M17+ M17+ 18 n/a Silent Hill: Downpour R16 MA15+ M17+ M17+ 18 M18 Sniper: Ghost Warrior R16 MA15+ M17+ M17+ 16 Suitable for 16 and above SOCOM: Special Forces R16 MA15+ M17+ M17+ 16 Suitable for 16 and above The Cursed Crusade R16 MA15+ M17+ M17+ 18 M18 The Saboteur R16 MA15+ M17+ M17+ 18 M18 The Witcher 2: Assassins Of Kings R16 MA15+ M17+ M17+ 18 M18 Tom Clancy's Ghost Recon Predator R16 MA15+ T T 16 General Tom Clancy's Splinter Cell: Conviction R16 MA15+ M17+ M17+ 18 Suitable for 16 and above UFC Undisputed 3 R16 MA15+ T T 16 General UFC: Undisputed 2010 R16 MA15+ T T 16 General Uncharted 3: Drake's Deception R16 MA15+ T T 16 General Warhammer 40,000: Space Marine R16 MA15+ M17+ M17+ 18 M18 Way Of The Samurai 3 R16 MA15+ M17+ M17+ 16 Suitable for 16 and above Yakuza 3 R16 MA15+ M17+ M17+ 18 M18 Yakuza 4 R16 MA15+ M17+ M17+ 18 M18 Yakuza: Dead Souls R16 MA15+ M17+ M17+ 18 M18 Aliens vs Predator R18 MA15+ M17+ M17+ 18 M18 Army Of Two: The 40th Day R18 MA15+ M17+ M17+ 18 Suitable for 16 and above Borderlands: Game Of The Year Edition R18 MA15+ M17+ M17+ 18 M18 Bulletstorm R18 MA15+ M17+ M17+ 18 M18 Call of Juarez: The Cartel R18 MA15+ M17+ M17+ 18 M18 Dead Island R18 MA15+ M17+ M17+ 18 M18 Dead Rising 2 R18 MA15+ M17+ M17+ 18 M18 R18 MA15+ M17+ M17+ 18 M18 Dead To Rights: Retribution R18 MA15+ M17+ M17+ 18 M18 Deadliest Warrior: Legends R18 MA15+ M17+ M17+ 18 n/a R18 MA15+ M17+ M17+ 18 M18 F.E.A.R. 3 R18 MA15+ M17+ M17+ 18 M18 Fallout: New Vegas R18 MA15+ M17+ M17+ 18 M18 Gears Of War 3 R18 MA15+ M17+ M17+ 18 M18 Heavy Rain R18 MA15+ M17+ M17+ 18 M18 Inversion R18 MA15+ M17+ M17+ 18 M18 Just Cause 2 R18 MA15+ M17+ M17+ 18 General

55 Office of Film and Literature Classification Comparing Classifications 2010 & 2011 Games cont/

Title NZ Aus USA Canada Pan-Europe Singapore Kane & Lynch 2: Dog Days R18 MA15+ M17+ M17+ 18 M18 Mafia II R18 MA15+ M17+ M17+ 18 M18 Payday: The Heist R18 MA15+ M17+ M17+ 18 n/a Rise Of Nightmares R18 MA15+ M17+ M17+ 18 M18 Saints Row: The Third R18 MA15+ M17+ M17+ 18 M18 Singularity R18 MA15+ M17+ M17+ 18 M18 Spec Ops: The Line R18 MA15+ M17+ M17+ 18 M18 Splatterhouse R18 MA15+ M17+ M17+ 18 M18 Supremacy MMA R18 MA15+ M17+ M17+ 18 M18 The Darkness II R18 MA15+ M17+ M17+ 18 M18 The House Of The Dead: Overkill Extended Cut R18 MA15+ M17+ M17+ 18 M18 Mortal Kombat R18 RC M17+ M17+ 18 M18 Syndicate R18 RC M17+ M17+ 18 M18

56 Office of Film and Literature Classification Comparing Classifications 2010 & 2011 Appendix C: 2008/09 Strength Scores

Table 13: 2008/09 classification strength scores for feature film classifications

Classification Strength Jurisdiction Classification Score Unrestricted Australia G 1 New Zealand G 1 Ontario G 1 UK U 1 USA G 1 Australia PG 2 New Zealand PG 2 Ontario PG 2 UK PG 2 USA PG 2 USA PG-13 3 Australia M 3 New Zealand M 3 Parental accompaniment (a restricted category) UK 12A 5 New Zealand RP13 6 Ontario 14A 7 Australia MA15+ 8 New Zealand RP16 9 USA R 10* Ontario 18A 11* Restricted UK 12 10* New Zealand R13 11* New Zealand R15 13 UK 15 13 New Zealand R16 14 USA NC-17 16 Australia R18+ 16 New Zealand R18 16 Ontario R 16 UK 18 16

* The 'overlap' in weighting is due to likely restrictiveness of each rating in practice: eg the likelihood that many under 13 year olds for example would actually see an 18A rated film.

57 Office of Film and Literature Classification Comparing Classifications 2010 & 2011 Table 14: 2008/09 classification strength scores for video game classifications

Jurisdiction Classification Classification Strength Score Unrestricted ACB G 1 BBFC U 1 ESRB Early Childhood 1 OFLC G 1 PEGI (UK) 3 1 ACB PG 2 BBFC PG 2 ESRB Everyone 2 OFLC PG 2 PEGI (UK) 7 2 ESRB E10+ 2.5 PEGI (UK) 12 3 ACB M 3 OFLC M 3 ESRB Teen 3 PEGI* 16 4 PEGI* 18 6 Parental accompaniment (a restricted category) ACB MA15+ 8 ESRB (USA)* Mature 17+ 9 Restricted BBFC 12 10 OFLC R13 11 BBFC 15 13 OFLC R16 14 ESRB (Ontario) Mature 17+ 15 BBFC 18 16 ESRB AO 16** OFLC R18 16 Banned ACB RC 20 OFLC Objectionable 20 BBFC Rejected 20

*Non-statutory/voluntary systems, however, encouragement/compliance to not sell to underage said to be high in the US, and encouraged in Europe. NB: Mature 17+ is legally enforced in Ontario. **While AO is a non-statutory classification in the USA, it is given the same strength as legal 18 restrictions here as there is strong (mostly) commercial/retail compliance. In Ontario it is a legal restriction. No AO games are included in the sample.

58