The BBFC has for some time now been accepting ‘Picture-in-Picture’ (PIP) commentaries, a function commonly found on HD DVD and Blu-ray releases. These are also sometimes known as PIP, IME (In Movie Experience) or U-Control. These are usually submitted on standard definition DVD.

Some commentaries are submitted in a finished form as the consumer will see them, with the main feature playing in the background and the commentary footage playing in a window. Due to technical considerations, some commentaries are not submitted in this way. Instead, the PIP footage is submitted separately from the main feature.

This has proved problematic in some cases as it is often not clear what the PIP footage relates to when it is divorced from the main feature and viewed out of context. This can make examination of the footage extremely difficult. In order to alleviate this problem the BBFC will view most PIP commentaries with the main feature playing on a separate monitor side by side with the commentary.

However, it is not practical to do this for all such submissions. For ‘scene specific’ commentaries (i.e. submissions where PIP footage appears only occasionally onscreen) we must now ask for paperwork detailing which scenes of the main feature the commentary refers to, with accompanying timecode references if applicable.

If the PIP commentary is supplied in a finished form then there is no need to submit this supporting paperwork.

Please contact the technical department ( technical@bbfc.co.uk ) for further information.

The BBFC has noted the different approaches taken by games companies with regard to ‘ports’. Some companies routinely seek a fresh classification for each version of a game, while others assume that the original classification will cover all ports of the game under the Video Recordings Act 1984.

The BBFC has therefore taken legal advice on the issue

Our legal advice is that each ‘port’ will require a separate classification certificate unless the changes are de minimis and make no material difference to the content of the game.

Our legal advice is that the following changes would be likely to be regarded as de minimis (provided they introduce no new contentious elements):

• Different menu/navigation/instruction screens
• Different disclaimers/copyright notices/logos
• Minor differences in background music

Our legal advice is that the following changes would not be likely to be regarded as de minimis:

• Different game content (including the addition or removal of characters, levels, backgrounds, effects, cutscenes, props, etc)

Please note that a ‘port’ of a classified game may require less examination time than the original submission and may therefore attract a lower fee.

In addition to payments by cheque and Bank transfer, the BBFC now also accepts payment online via Visa, Mastercard, Maestro and Solo. The details can be found by clicking on the link within the customers section of the website

Should you have any queries please contact our Finance department on: finance@bbfc.co.uk

The BBFC is accepting submissions on DVD as from January 1st 2006. As a result of this there is no need to submit works on DVD with a burnt in time code, the DVD counter time providing the same information.

Removing the burnt in time code on a digital version could be seen as potentially increasing the opportunity for untraceable piracy of the material to occur. The presence of a time code instantly demonstrates that this is not a released version of the product.

The BBFC is confident that its security measures are sufficient. The BBFCs procedures have been accredited by the Federation Against Copyright Theft to that effect. The BBFC cannot, of course, guarantee the security of material before it reaches our premises and fully appreciates the video industry’s concern than untraceable piracy could occur.

There has been a long standing objection to the use of DOGs as these are often deliberately designed to be large and intrusive. This is understandable as an anti-piracy measure but renders the work unusable for classification purposes.

In the light of our shared concerns the BBFC is now prepared to accept DOGs on submissions, subject to the adherence to the standards laid out below.

The overriding principle is that no DOG should obstruct the visibility of any significant material. Regardless of other points if a DOG does obstruct significant material then the work will require resubmission with the DOG adjusted or removed as necessary.

The DOG must be in the top right or top left hand corner of the picture.

The DOG must not extend over more than the top 20% of the image, or over more than 35% of the width of the image from the nearest edge.

The DOG must be static, not scrolling, flashing or otherwise dynamic.

The DOG must be white and have a transparency of 50%.

Text in the DOG is to be limited to 10 characters. A code of “copy 2263″, a company name or abbreviation is acceptable as is a unique code generated for the copy or any other text, though limited to ten characters. This limit helps to ensure that the DOG is comparable with a time code in screen space used. The DOG must not contain an explicit reference to the BBFC (eg ‘BBFC COPY’ or ‘CENSORCOPY’).

Text in the DOG must not be in an excessively large font.

The following examples illustrate DOGs which are acceptable and DOGs which are unacceptable under this policy.

Acceptable Examples

Example 1

Example 2

Example 3

Unacceptable Examples

Excessively large font

Example 4

Example 5

Extending beyond designated area

Example 6

Example 7

Should you have any questions regarding this information please contact the Technical the customer helpline on 020 7440 0299 – option 2 or email technical@bbfc.co.uk

In response to industry concerns about piracy, the BBFC started to accept works containing Digital Onscreen Graphics (DOGs) at the beginning of 2006. The criteria for acceptance was clearly set out in our Policy document dated December 2005.

Whilst this has been largely successful in achieving industry objectives without excessively impinging upon BBFC classification needs, it is appropriate to remind the industry again of these criteria, particularly regarding the placement of DOGs. Our criteria here is absolutely clear: “The DOG should not extend over more than the top 10% of the image, or over more than 25% of the width of the image from the nearest edge.”

Please note that from 1st August 2007 we will be strictly applying all DOGs criteria as laid out in the policy which can be found at: http://www.bbfc.co.uk/news/stories/20051219.html

Works which do not comply with our criteria will be refused by the BBFC technical department.

The Department for Culture, Media and Sport has given the Board permission to amend the tariff of classification fees with effect from 8 January 2007. The overall net effect is to increase charges by 10%, though the effect on individual customers will vary according to the nature of the submissions made. This will be the first time the fees have been increased since 1998 and follows substantial fee reductions amounting to 30% over a period of three consecutive years from 2002 to 2005.

This increase is necessary to ensure that quality of service is optimised through continued investment in the Board’s activities.

Under the terms of the Video Recordings Act 1984, we are required to keep a statutory archive of video tapes of works classified. This archive is not only at risk of degradation as the video tape itself deteriorates, but because of the changes to technology it is getting more and more difficult to replace the specialist video equipment used to play the tapes. As well as being vital to our classification work, the archive is necessary to enable trading standards officers to pursue illegal trading in videos and DVDs. To that end the Board has embarked on a project to digitise its archive. This will involve a considerable ongoing cost to the Board. The move to digital cinema will also require significant investment in digital projection equipment.

In addition the Board has reviewed the fee structure and has identified anomalies which need to be addressed. The result is a restructuring of the fee tariff as follows:

the introduction of a handling fee to cover the different fixed overhead costs associated with the different mediums.
the replacement of the sliding rate scale with a fixed charge per minute; and
the withdrawal of the concession rate currently applied to foreign language works and certain British television programmes.

With regard to the withdrawal of the concession rate it should be noted that the cost associated with the classification of such works is no lower than for works previously denied the concession. In fact, for many foreign language works, the Board incurs an additional direct cost through the need to engage interpreters.

Full details of the changes are as follows:

The fee for Technical Comparisons and Distributor Change will remain unchanged but will attract a handling fee of £75.

Questions and Answers

Q. If a work is audio descriptive. i.e., is intended for a sight impaired audience, is this eligible for the charity rate ?

A. Yes, this is an extension beyond the concession for registered charities.

Q. If a work is submitted on behalf of a registered charity, e.g., by an advertising agency, is this eligible for the charity rate ?

A. Yes, but the submission must be accompanied by evidence that the work is submitted on behalf of a registered charity. This must include the registered number of the charity.

Q. Why are film and digital media change of distributors charged at the standard rate ?

A. The principle is that works that must be viewed are charged the standard rate. Works that can be compared at the technical stage need not be viewed and cost significantly less to process. Film and digital media works cannot be compared side by side and must be viewed.

Q. Secondary classifications are now being charged at the same rate as distributor changes. Why is this ?

A. When the secondary process was introduced a number of these works required viewing to confirm differences were not material. With improvements to the process viewings are now largely unnecessary and a comparison only charge is now appropriate.

Q. Do advice viewings lose the concession ?

A. Advice viewings are charged at 75% of the standard rate.

Occasionally, video recordings (including DVDs, video games, etc) may contain added value material which raises significant classification issues which did not arise in the main feature. This is particularly likely in circumstances where added value material is classified at a category higher than the feature. For instance, a director’s commentary or blooper reel may contain use of strong language which attracts a ‘15’ category even though the main feature is a ‘PG’ film with no strong language. In such circumstances the Consumer Advice (CA) written for the main feature will not accurately reflect the content of the video recording as a whole.

To avoid customer confusion, if planning to release a video recording containing added value material which raises significant classification issues which did not arise in the main feature and which are not referred to in the CA, it is recommended that distributors take one of the two courses of action set out below:

Request consolidated CA to cover all the content on the video recording. The BBFC will provide this free of charge on receipt of an email to consumeradvice@bbfc.co.uk listing the VFC numbers of the individual video works to be contained on the video recording; or

Qualify the CA as shown below

NB In circumstances where added value material has been classified at a higher category than the main feature, distributors should continue to make this clear through the use of text such as ‘main feature classified PG – added value material classified 15’

Should you have any questions regarding this information please contact the customer helpline on 020 7440 0299 or email helpline@bbfc.co.uk

Due to the interactive, non-linear nature of Video Game submissions, the BBFC examines them in a different way to film and video, with examiners sampling different levels and areas of gameplay in order to build up an accurate indication of the issues contained within the game. This sampling is due to the fact that, for most games, viewing every possible element would be extremely difficult in terms of time and logistics.

Where there is linear material (commonly referred to as a ‘cutscene’) in a game, this is viewed in full, as it triggers none of the difficulties associated with non-linear material.

As more and more games are featuring cutscenes generated dynamically within the game engine, rather than using pre-rendered footage, the time has come for the BBFC to clarify our position on what is required as part of a Video Game submission in order for us to ensure we are viewing all necessary footage.

We have taken this opportunity to update our Video Games Submission Form, which further clarifies the supporting material required as part of a submission, and requires confirmation that the game being submitted is content complete. The updated Submission Form will go live on the BBFC website on September 18th, and should be used for all Video Game Submissions from that date forward.

The following explanatory notes explain our definition of cutscenes and clarify our submission requirements for Video Game Submissions. As of September 18th, these notes will replace those currently appearing on the BBFC website in the Video Game Submission section.

Should you have any queries regarding this updated process please email ithelpdesk@bbfc.co.uk

Guidance notes

The following is required for each video game submission;-

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

Content complete code

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

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

Filling in the submission form

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

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

Additional Information

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

Cutscenes

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

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

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

Unlockable content & Extras

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

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

Supporting Material

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

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

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

Failure to provide adequate supporting material will delay the submission.

Gameplay footage

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

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

IT Assessment

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

The BBFC would like to give early notice to its customers in announcing our intention to cease accepting VHS as a submission format from 1st July 2007.

With VHS coming to its end in the marketplace, it is becoming increasingly difficult for the BBFC to maintain the technical capacity to deal with VHS submissions. Professional VHS equipment is now obsolete. We need to concentrate the resources we have on being able to continue to undertake comparisons on behalf of the enforcement agencies.

The Board started accepting DVD at the start of 2006. DVD now makes up over a third of our submissions. Customers who submit on DVD range from the largest, to our smaller customers who submit a handful of works a year. If the same growth in DVD submissions continues through to July 2007, VHS submissions will have virtually ended. In announcing our intention at this early stage, those in the industry still submitting on VHS can work towards beginning to submit their work on DVD before the July 2007 deadline.

Should the deadline create a problem for any of our customers please email me.

Details were posted on the Board’s website when DVD submissions were first introduced. It contains very important information on the technical requirements for making DVD submissions to the BBFC.

For the BBFC to offer its games customers the most efficient service we must receive the complete submission. Some recent games have been submitted without direct access to cut scenes which has lead to delays in the classification process and endangered release dates.

Please can we take this opportunity to remind you to submit all cut scenes within any games submission in either one of two ways;

a – Within the debug game itself and accessible via the debug menu

or

b – On a DVD or VHS as a supplement to the game

Should you have any queries regarding this matter, please email ithelpdesk@bbfc.co.uk

The BBFC has recently reviewed the ways in which it handles cases submitted by law enforcement agencies for Certificates of Evidence.

Under our current process, a law enforcement agency can submit up to 10 seized works per case for evidence as well as an unlimited number of titles. After discussions with LACORS, it has been agreed that we will now accept a maximum of 8 seized works per case. Additionally, we will supply title-only evidence according to a new maximum number of 200 titles per case. This change will come into effect from 1 July 2006.

With these measures, we aim to be able to provide evidence more speedily, and on a larger number of cases overall.

This document deals with the procedure to be adopted in cases where submitting companies are dissatisfied with the determination made by the Board in respect of their work. The BBFC offers a formal ‘reconsideration’ procedure which is open to any distributor dissatisfied with the determination made in respect of their work . The reconsideration is free of charge and will normally take less than 10 working days. A distributor may also appeal directly to an independent authority. Such an appeal make take place following, or instead of, a request for reconsideration by the BBFC. The procedure for film and video works (including DVDs, video games, etc) is slightly different because of the different legislative frameworks. Distributors should note that a reconsideration or an appeal involves looking at the issues afresh. This means that the outcome could, in some circumstances, be more restrictive than the original determination. Full details are available in the downloads section of the website.

Having recently increased our projection team resources, we are now in a position to improve the service to film customers and extend the print delivery deadline from 1pm to 5pm on the day before the film is booked in for viewing.

Please note the new extended 5pm deadline will be strictly adhered to by the BBFC. This means that any film delivered after 5pm will see the screening being postponed until the next available viewing slot. Requests for late delivery must be made at least two working days before the film is due to be viewed by the BBFC.

We hope this extension proves useful to you and should you have any questions please email the Customer Helpline (helpline@bbfc.co.uk).