Classification categories under the proposed classification system

9.6 In the Issues Paper, the ALRC asked about the community’s understanding of the existing categories and the merits of other possible classification categories.^[10] Many submissions argued that classification categories are not themselves a significant problem. The Arts Law Centre of Australia, for example, observed that the current classification categories are well-promoted and appear to be well understood.^[11] Civil Liberties Australia said there is little need for new classification categories.^[12]

9.7 Some submissions cautioned against major change in this area, because significant resources have been expended since the early 1990s to harmonise classification categories across media (for example, between television and films and computer games) and to educate consumers about their meaning.^[13] The Australian Home Entertainment Distributors Association (AHEDA) submitted that it ‘would not support any changes to a system that is on the whole well understood and supported’.^[14] The Australian Subscription Television and Radio Association (ASTRA) thought that additional or merged categories would cause confusion, and submitted:

there would need to be compelling evidence that the current categories are ineffective or inappropriate, and that a reconfiguration of categories would be more effective, before any substantial changes are contemplated.^[15]

9.8 On the other hand, there were submissions that pointed to the need for better descriptions of each classification category to assist consumers in distinguishing between existing categories. Others suggested that age references be incorporated into the classifications. In particular, numerous submissions identified the M and MA 15+ classifications as problematic, as discussed below.

9.9 Many submissions called for the introduction of an R 18+ classification for computer games. In July 2011 Commonwealth, state and territory censorship Ministers agreed to introduce this classification for computer games. This is consistent with the ALRC’s proposed classification model. Many submissions also questioned the scope of the RC category. This is discussed separately in Chapter 10.

9.10 Well understood categories are essential if a classification system is to inform and guide people’s entertainment choices and assist parents to choose content for their children. The ALRC considers there is merit in modifying the names and markings of some of the existing categories in order to achieve greater clarity and better fulfil the consumer information role of classification—particularly for parents.

PG 8+

9.11 Some submissions proposed that age references should be included as part of the classification, to provide a better guide for parents and carers on the suitability of content for children.^[16] Currently, the only film, television and computer game classifications that have age references built into the classification marking are those categories with legal age restrictions: MA 15+, R 18+ and X 18+. While the classification guidelines include recommendations of appropriate ages for the other classifications, this information is arguably unhelpful, because ‘too many categories centre around the age of 15 years’.^[17]

9.12 The ALRC agrees that adding unique age references to the categories and markings will provide greater clarity and consistency of appearance across all the classifications. This will assist consumer understanding of the categories, including how they relate to each other.

9.13 The ALRC therefore proposes that, in addition to the T 13+ category proposed below, the PG category should be amended to incorporate the age reference 8+.^[18] The classification guidelines might also state that parental guidance is recommended, but this content is not recommended for persons under eight years of age.

M, MA 15+ and T 13+

9.14 Many submissions stated that the M and MA 15+ classifications are confusing. It is important that parents and guardians understand the difference between these classification categories because MA 15+ content is strong in impact and not suitable for persons under fifteen.

9.15 MLCS Management, for example, stated that ‘the overlap/confusion around M and MA 15+ should be addressed’.^[19] Another submission suggested ‘at least change the M letter in one of them to avoid confusion’.^[20] SBS suggested that the confusion arises because ‘the M category is not recommended, while the MA 15+ category is not suitable, for people under 15 years of age’.^[21]

9.16 The MA 15+ classification was introduced in 1994 to address community concerns about the significant gap between the M and R 18+ classifications. There was particular concern that stronger content that did not warrant restriction to adults, but was nevertheless unsuitable for persons under 15, was being wrongly classified as M. Similar concerns have been cited in support of an R 18+ classification for computer games.^[22] If, on the other hand, the M classification were removed, a similarly problematic gap would exist between PG and MA 15+ content.

9.17 Rather than remove a category, the ALRC proposes renaming the M classification as ‘T 13+ Teen: Teenage audiences and above’. The classification guidelines for the T category should be amended to state that ‘T classified material is not recommended for persons under 13 years of age’. This proposed change clearly distinguishes the classification from the MA 15+ classification in its visual representation, the category descriptor and by referring to a different age.^[23]

9.18 ‘Teen’ has particular utility as a familiar term that is intuitively understood to mark a stage of life often associated with developmental milestones such as commencing high school. There was support in submissions for a category that referred to age 12 or 13 years,^[24] and similar categories exist in the computer games classification system in the US and Europe and for the film classification system in Britain.^[25]

9.19 While the current classification guidelines explain that material classified M is not recommended for persons under 15, and this would change to age 13 under the above proposal, the Australia Council on Children and the Media suggested age 13 as the appropriate age for moderate impact content in its recommendations for changes to categories. This is consistent with the moderate impact threshold for the current M classification.^[26]

9.20 The ALRC proposes that the MA 15+ classification should be retained unchanged except that the category descriptor should be amended from ‘Mature Accompanied’ to ‘Mature Audience’ and the black ‘restricted’ tag removed from the marking. This change is necessary to reflect the proposal in Chapter 8 that the MA 15+ classification no longer impose legally enforceable access restrictions (although the classification guidelines should continue to state that content at this classification is not suitable for persons under 15). Changing the reference to ‘Mature Audience’ also achieves consistency across media platforms—this is the meaning of the MA 15+ classification as applied for some time under most of the television codes of practice, including subscription television.

C (Children)

9.21 The C (Children) and P (Preschool Children) classifications are currently only used by free-to-air commercial television networks. These classifications are in addition to the G classification which is used across all the classification regimes. C and P classifications are granted by the Australian Communications and Media Authority (the ACMA) on application. C and P classified programs are different from material produced for a family or general audience. They are not simply ‘suitable for’ children, but designed specifically to meet children’s needs and interests.

9.22 A television program may carry the C or P classification if approved by the ACMA and if it satisfies the requirements of its Children’s Television Standard (CTS),^[27] which includes that it:

• is made specifically for children;

• is entertaining;

• is well produced using sufficient resources to ensure a high standard of script, cast, direction, editing, shooting, sound and other production elements;

• enhances a child’s understanding and experience; and

• is appropriate for Australian children.

9.23 AHEDA submitted that content designed for children ‘should be industry self-assessed and it should apply and be consistent across all platforms’, indicating that some content providers may be interested in using a children’s classification for certain media content.^[28]

9.24 It is also inconsistent that the ABC, SBS and subscription television services use the G classification for children’s programming in accordance with requirements set out under their respective codes of practice; and the Board uses the G and PG classifications for content that is appropriate for younger children in accordance with criteria as set out in the classification guidelines for films and computer games. Free TV Australia maintained that:

television programs granted a C certification by the ACMA (as required under the CTS), are regularly classified as PG by the Board. This causes difficulty for free-to-air broadcasters, who will often be influenced by the Classification Board in their own classification decisions, and increases the likelihood of accidental breaches in cases where the ACMA and the Board have different views on the same piece of content. It also creates confusion for viewers, who may be unclear as to the appropriateness of material where different classifications apply in different formats.^[29]

9.25 The ALRC considers that consistent and targeted classification information that is useful to parents, such as that provided by a children’s specific classification, should be encouraged, particularly if it leads to more media content being classified. A more widely used C classification might have other benefits, such as assisting content providers or parents to establish ‘white lists’ of safe, child-friendly online content. Parents and carers can also be confident that they are selecting content exclusively for young children as distinct from G content that is not always or necessarily intended for children.

9.26 The ALRC therefore proposes the inclusion of a C category that may be used by all classifiers under the new National Classification Scheme.