The Japanese agency for the issuance of age ratings, CERO, recently suspended its activities due to the coronavirus outbreak. This can be a big problem for developers that have planned a release of their not-yet-rated game in Japan. Nekki‘s project manager Sergei Sorokin shares his experience, tells which documents you need and describes possible difficulties for game publishers, who need to get an age rating in Japan.
In order not to bore you with a long story about all the existing international age ratings (especially since I personally didn’t work with all of them), I’ll start right away with the most interesting and lengthy case - getting a rating through the Japanese agency CERO. I will tell about all other rating agencies in the second half of the article.
But first an important note on three points:
- As a basis, I will take the release of our fighting game Shadow Fight 2 for the Nintendo Switch and try to explain about each individual agency associated with this particular release.
- My report is only about digital releases, not physical ones. Age ratings for physical copies can have both other processes and other restrictions.
- We started applying for a CERO rating in mid-2018 already. In general, I assume that the process didn‘t change much, but I think it's important to mention this particularity.
The Computer Entertainment Rating Organization (CERO) is a rating agency in Japan. If you want to publish your game on consoles in this country, you must apply for their age rating.
Be prepared for all communication and documentation to be in Japanese. You really shouldn't rely on "Google Translate" in this situation. It is better to find a person with Japanese language skills or a localization studio to support you.
To start the application process, go to this website and write in Japanese who you are and what you want. They respond fairly quickly, we didn't wait longer than 3-5 days for the first answer. They explain to you in detail what options there are for getting an age rating. Actually there are two of them:
- One time payment. This option is the right choice if you only need a single rating for a game and for one (or more) platform. The cost for this was around 2,000 euros in 2018.
- Membership. This option costs both a membership fee and a contribution for each game rated. But the price for rating each game is lower than the one-time rating. That said, if you plan to request 5-7 releases on 3-4 platforms in the future, you should consider the membership in this agency.
We chose the first option for Shadow Fight 2.
After deciding which option suits you best, you will receive a physical envelope with printed documents. The mail came very quickly from Japan to our office in Cyprus. The envelope contains a number of documents, including: a contract, a description of how to make a video, a questionnaire on the details of your request, and a document that describes what you should send back (e.g. a general description of the game, which I will discuss below) and so on.
We will discuss each point separately.
- Contract. Nothing unusual here. Translate the contract from Japanese (for yourself), check it and sign in the right places.
- Video. This is the main task. The video is required to visualize the various aspects of your game.
The video should be 15 to 120 minutes long.
Size - not more than 4.5 GB;
Ideally, the entire game should be shown in as much detail as possible - preferably all types of equipment, clothes, faces, weapons, locations, the user interface, cutscenes, intro videos, etc .;
If you have even a hint of nudity (e.g. bare breasts), blood, death (when a character dies), murder, mutilation, and other such delicate content, you must show this in the video.
Everything in the video has to be in Japanese, otherwise you have to provide conclusive reasons why you don't have Japanese in the video if you are asked additional questions later (more on this below).
Here are a few tips on the subject of the video:
We have divided our video into five parts by category (user interface, "tutorial", etc.) for easier understanding.
We also added Japanese timestamps to the video, making it easier for reviewers to find a segment of the video. We also sent the video in physical form. Yes, you read that right: you have to burn the video onto a DVD and send it to Japan. I asked the CERO whether it is possible to transmit the video in any other way. I was told that this is the usual procedure that cannot be deviated from - so please send a DVD. (If you find a store that still sells some)
- Summary. Text description of the game.
Requirements: Describe briefly what your game is about. Do not use advertising text from the appstore description, but you can use lively language: "Our hero has to save the princess, for this he will go through eight kingdoms, defeat this and that, and the end will be so and so. Management in the game is so and so. For most of the game, one-on-one battles await the player ... and so on. "
This short game description must of course be submitted in Japanese. Length of the summary is not set, so just make it. As a guideline for the text length, I can share our own description in English with you (or did you need Japanese?). Based on this description, our application was approved on the first try and no additional questions were asked. Description of Shadow Fight 2 for Nintendo Switch.
A standardized questionnaire must also be completed for the application to review the game.
This form is enclosed with the envelope that was sent to you by post at the beginning. In the form, you need to specify which console to test, the total length of your video, and a number of other details.
Since there is only one copy of the document enclosed, I would recommend translating it into English first and noting the necessary information there, and only later translating the final version into the original.
If you don't want to wait, you can send the envelope with the contract to Japan immediately and send your video after a while. The order doesn't matter, but the main thing is that the signed contract is sent in the first letter.
So, your finished materials are: DVD, summary, questionnaire and contract. Now all you have to do is send everything back to the CERO office and wait for an answer.
You will receive answer after 1-2 days, when their receive your enveloper. Officially, the game review takes up to 10 working days. But there are conditions:
- The review only starts after receipt of payment.
- The review only starts after any additional questions from their side have been answered and all problems have been resolved.
- Additional questions may also come from the reviewers after watching the video: most likely they concern the "adult" part of the game.
In Shadow Fight 2, for example, there is a winter location with huge blocks of ice on the back. In these ice blocks you can see the silhouettes of dead people. So we were asked, "Why are they these people dead and why are they in the ice blocks?" At another point in the game there is a text that says, "I will tear you to pieces!" So we were asked the following question: "Is this threat really being carried out and how is it displayed in the game?" So be better prepared to answer even such questions.
After resolving any issues, you will have to wait approximately 10 days and you will receive a PDF file detailing your rating. If you confirm that you agree to the decision, you will receive an envelope with the PDF document in physical form, as well as a series of documents and descriptions on how to use the age rating for various purposes.
You must state on this physical copy that you agree with the classification. Then you have to send the PDF (this time by email!) back to the CERO department. By this, you officially confirm that you have no complaints and agree to the result.
At this point, the evaluation process for Japan is complete. Congratulation!
If you disagree with the CERO decision, the process starts again and you have to make another payment for a second review.
In general, the whole process took about two months, taking into account the time spent on the video and summary. Answers to all questions you may send to the CERO agency come fairly quickly. And at any time of day, even outside of Japanese business hours. The experts there are ready to answer appropriately and explain to you what is required for each step.
You may ask, is it recommend to publish a game in Japan and put up with the effort of an age rating? Of course, this depends on the product and your priorities. In Nekki‘s case, 10% of the game's purchases came from Japan, although Japan wasn't even one of the ten profitable markets in the mobile version of Shadow Fight 2.
More rating agencies
Although CERO is the most time-consuming task on my list, we mustn't forget the other important age ratings that are required for almost every international game publication.
Let's start with the simplest and broadest coalition of agencies in the International Age Rating Coalition (IARC).
This coalition includes all the major rating agencies in the world:
Pan European Game Information (PEGI) - issues age ratings in 38 European countries (and several others);
Unterhaltungssoftware Selbst-Kontrolle (USK) - gives age ratings in Germany;
Entertainment Software Rating Board (ESRB) - gives ratings in America, Canada and Mexico
Classificação Indicativa (ClassInd) - gives ratings in Brazil;
Australian Classification Board (ACB) - issues ratings in Australia;
Game Rating and Administration Committee (GRAC) - issues ratings in South Korea;
The IARC also gives its ratings for countries in which there are no relevant agencies.
Depending on which game you publish (mobile devices or console), you have to go to the appropriate platform (e.g. Google Play where you want to publish your application) and request such a rating. All you have to do is fill out a form to answer a few questions about your game, and in just a few minutes you will receive all of the above ratings.
It is important to consider a few points:
The same application on a mobile device and on consoles are still different products. You must therefore apply for ratings separately.
It's also worth knowing the limitations of IARC: for some platforms, all of the above age ratings are issued by IARC, but for some there are exceptions.
In some cases you need to contact the agencies directly. Below I will tell you which one.
The Office of Film and Literature Classification (OFLC) is a rating agency in New Zealand. Usually these take over the rating from Australia, but if your game is "15+" or "18+" you should contact this agency directly to clarify the situation, in other cases ACB is sufficient.
The British Board of Film Classification (BBFC) is a British rating agency. But there are reservations. Officially, the VSC Rating Board (VSC), which is part of PEGI, is responsible for rating games. However, if your game is "18+" (if there is pornographic content), it will be rated by BBFC. In our case, the game on the Nintendo Switch is not "18+", so we didn't have to request a rating.
Russian Age Rating System (RAR) - an "agency" for obtaining a rating in Russia. I put the word agency in quotation marks because every developer actually sets a rating for himself. In some cases, when checked by the agency, there may be a problem in the form of a fine (for example, you have a game for the age group "16+" and you set "3+"). However, if you look at the PEGI rating for comparison, you can very well guess which rating you should set to bring your game to the Russian Federation.
Game Rating and Administration Committee (GRAC) - South Korean rating agency. To get a rating in Korea, you need a country employment office or a Korean publisher. However, there are exceptions for digital publications.
Game Software Rating Management Regulations (GSRR) is a rating agency in Taiwan. We can confirm that this rating also applies to Hong Kong and Southeast Asia. In some situations, for Hong Kong you can also use the ratings of agencies that have already been obtained in other countries. From my own experience I can say that the main problem is time. The registration request in the system can take a month.
General Commission for Audiovisual Media (GCAM) - Games in Saudi Arabia also need an age rating. We have not requested GCAM's Shadow Fight 2 rating, but we have heard from colleagues that it is perfectly possible to use the PEGI rating in Saudi Arabia as well. If we need it, we will most likely try it out first with the PEGI assessment.
In addition to all of this, there are other agencies, but firstly, they are used much less often, and secondly, we have not tried them personally, so I cannot provide any precise information. You can find detailed information on the rating agencies not specified on Wikipedia.
Finally, I would like to say that our next project, Shadow Fight Arena, which we are developing together with Banzai Games, will be cross-platform. It is to be published on mobile platforms, PCs and consoles. Therefore, we will again face up to the challenges mentioned in this article and will probably also meet new agencies with whom we have not previously worked. So if the topic has sparked your interest, I will be happy to tell you more about our new experience at a later date.