Protocol | China

Why doesn’t China have a video game rating system?

To the government, a rating system means less control, not more.

Person holding game controller

Video game fans and developers in China have long called for a rating system.

Photo: Kelly Sikkema/Unsplash

More bad news for China's teen gamers: with summer break ending soon, Beijing just published the strictest-ever regulations to limit gaming time for minors. On Aug 30, China's National Press and Publication Administration declared that anyone under 18 will only allowed to play games between 8pm to 9pm on Friday, Saturday and Sunday.

To enforce the new regulations, NPPA is asking game providers in China to block underage gamers from accessing those developers' own games, a move that would require identity verification technologies. It's much more complicated than the solution widely used outside China: a universal game rating system. So why doesn't the country have one already?

Video game fans and developers in China have long called for a rating system similar to those in the United States or Japan. Since 2004, many Chinese institutions, from state-affiliated industry associations to academic research centers, have tried to propose one that suits China. Yet nearly two decades later and with a $43 billion video games market, China is still only on the edge of having it in place, despite a government obsession with protecting children from video games. What gives?

The short answer is that while a rating system means more restraint on video games in the West, it would lead to the opposite result in China. Regulators there are accustomed to having strict control over any content being produced. A traditional rating system, usually based on voluntary disclosure, actually grants game developers more flexibility and enables uncertainty — the very thing regulators fear the most.

Meanwhile, both the regulators and gaming companies have come up with other ways to cut down children's game time to the extent that maybe adding a rating system is not going to have much impact now.

Unfinished attempts

For the past two decades, China's gaming industry has appeared to go in circles when it comes to attempts to develop a rating system.

Serious discussions started as early as 2004, when two separate government-affiliated groups took it upon themselves to research the system. One was led by the government-backed China Consumers Association, the other by the party-affiliated Communist Youth League of China. The latter released its draft rating system in November 2004, and it looked very similar to what gamers are used to today outside China: four levels from family-friendly to 18+, plus an extra level for games that are deemed "dangerous" and need extra monitoring but are still allowed to release.

It never went anywhere.

Then in 2010, the Institute for Cultural Industries at Beijing-based Peking University proposed its own comprehensive, 20-criteria rating system. In 2011,, a Communist Youth League affiliate website, started reviewing over 6,000 existing games using the criteria it developed. In 2019, the party mouthpiece People's Daily, along with support from major Chinese gaming companies like Tencent and NetEase, released another version of a rating system. But none of these proposals made it to the implementation stage.

The government only responded publicly to one attempt: In 2010, China's then Ministry of Culture (now called the Ministry of Culture and Tourism) told the media that it had no plan to replace the current approval system with a rating system. "Regulators have been conducting strict content reviews of online games, which is the foundation to guarantee the public and the society are served with healthy, beneficial online games," the Ministry's affiliate paper China Culture Daily quoted a ministry official as saying at the time. "This is fundamentally different from a 'rating system' and shouldn't be seen as the same."

"The government is not willing to let go of the [market] control," Zhang Chundi, gaming analyst at London-based research firm Ampere Analysis, told Protocol. He explained that most rating systems involve an industry association that designated age-based labels for games, but Chinese regulators are wary of transferring such power to a private organization.

Instead, in today's China, the government exercises strict control over the release of new games through a pre-approval system. In 2020, about 1,400 games were permitted to enter the market, of which only 97 were imports. Developers have long been complaining about the process, which can take several months and is seen as a black box. This is especially hard for independent game developers as the uncertainty and wait time can overwhelm a small studio with less of a financial buffer.

So when developers call for a Chinese rating system, what they have in mind is getting clear instructions on what is allowed for each age category. This would ultimately shift more agency to the industry, which is why the government opposes it.

In 2016, a Shanghai-based gaming developer even crowdfunded over 50,000 RMB (about $7,700 today) to sue China's content review authority over the lack of clear rules. The developer scaled back his plans after consulting lawyers, merely submitting a public letter to the State Council that laid out the claims of indie game developers. That effort also went nowhere.

New toolboxes

In the absence of a rating system, China has developed its own unique methods to keep children away from video games. It's one of the only two countries to have a state-ordered anti-addiction system — and Korea just decided to retire its "shutdown law" this week — that combines identity verification and back-end control to limit how long a child can play games each day.

This new regime started with a voluntary act by the gaming companies. In 2017, Tencent announced it would limit the play time of children under 12 to one hour per day and two hours for those under 18. Similar practices soon spread to most major game developers eager to show they were "doing their part" to protect children.

But a vicious cycle ensued in which underage gamers found loopholes in the system, media exposed them and companies like Tencent then announced the latest technology-enabled patch to fix it. Today, Tencent boasts using AI, machine learning, facial recognition and other advanced technology all to stop children from playing their games. It also released its first game, a dating simulation, that banned anyone under 18 to even play it. Yet it is still frequently accused of not doing enough.

The anti-addiction system has also grown from an operation discrete to each company into a centralized one managed by the Party's Publicity Department and connected to over 10,000 games available in China. It means teenagers who like to play games are always being watched.

Can this time be different?

Everything seems to suggest that China is now at its closest to finally having a video game rating system, even though it doesn't call it that.

In December 2020, the China Audio-Video and Digital Publishing Association, an affiliate to the government body that grants games approvals, released the latest iteration of a rating system. This time, there are only three categories: 8+, 12+ and 16+.

"I think this is definitely the one that will become the closest to an ESRB or PEGI style system," — the systems in use in the United States and Europe — said Daniel Ahmad, senior analyst at the Asia-focused gaming consulting company Niko Partners. "The key aspect here is that it's very different to the West because this system does not impact the content moderation regulations in place today. So a 16+ game cannot have anything that a normal 18+ game would have."

Over 350 games have been included in the trial of this system, the majority of which are mobile games. But while much anticipated, the latest stab at a ratings system is probably not what the game developers had hoped for. It won't replace the existing rigid content review process, and means little for underage gamers. The only group who may celebrate it is probably the parents, who can now point to a small label and tell their children: This game is not for you.

Update, Aug. 30, 2021: This article was updated to include new regulations released Aug. 30.

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