Issues with the BBFC’s 2018 Consultation Exercise

by Steve Jones, Northumbria University, UK

In 2018, the BBFC undertook a public consultation exercise that will inform its 2019 Classification Guidelines. [1] Thus far, journalists have over-reached in their reactions to the exercise. To illustrate, various press outlets erroneously declared that films featuring sexual violence will be automatically allocated an 18-certificate under the BBFC’s 2019 guidelines. [2] Both the Daily Mail’s Emily Kent Smith and The Daily Telegraph’s Charles Hymas refer to (but fail to substantiate) the motivating factors for the as-yet unconfirmed shift in BBFC policy, pointing towards ‘widespread concern that current age ratings are sometimes misjudged’ and ‘public backlash over “liberal” classifications following the #MeToo movement’. Hymas’s reference to #MeToo conflates real-world sexual assault with fictional representations of sexual violence. #MeToo was certainly driven by discussions about sexual assault within the film industry. However, outrage over real-world incidents of sexual assault does not directly equate to concerns about representations of sexual violence in fiction film; the latter may be of concern to ‘the public’, but the #MeToo campaign does not evince any such concern. Moreover, any change in BBFC policy would only impact on how films are classified; it would not directly curb instances of sexual assault within the film industry, for instance. Conflating real-world sexual assault with fictional representations is unhelpful inasmuch as it distracts from the campaign to prevent real-world sexual violence by changing working conditions within the film industry (and beyond).

Setting aside the press’s unhelpful interjections, the BBFC’s consultation exercise raises questions over how the organisation ought to handle fictional representations of sexual violence. Those questions are contextualised by the previous BBFC consultation exercise (in 2012), which ‘found that members of the public find unacceptable certain depictions of sexual and sadistic violence which, in their view, have the potential to cause harm’. [3] The 2012 consultation exercise was preceded by an unusually high number of classification rejections, each of which were predicated on what the BBFC identified as sadistic sexual imagery. Rejected titles include Murder-Set-Pieces (Nick Palumbo 2004, rejected in 2008), Nf713 (China Hamilton 2009, rejected in 2009), Grotesque (Kôji Shiraishi 2009, rejected in 2009) and The Bunny Game (Adam Rehmeier 2011, rejected in 2011), none of which have been classified in the UK to-date. [4] Such rejections arguably imply either that a significant volume of ‘sadistic sexual’ imagery was being submitted to the BBFC at the time, or that the BBFC were particularly sensitive about classifying such imagery. Both propositions are supported by a further contextualising factor: press furore over such representations. Journalists criticised the BBFC for not taking severe-enough action against such imagery and railed against the alleged proliferation of such imagery in the years preceding the 2012 consultation exercise. [5] Thus, the BBFC faced public pressure to reflect on how they handled depictions of sexual violence.

The Bunny Game (Adam Rehmeier 2011)

The 2018 consultation exercise was not preceded by the same indicators. BBFC Chief Executive David Austin asserts that the organisation holds ‘92 per cent approval ratings [for classification decisions]’. [6] If this statistic is accurate, it seems that the public overwhelmingly concur with the BBFC’s judgements. The approval rating certainly does not suggest that the public are overly concerned by the BBFC’s current policies. Smith also notes that ‘ratings tightened when scenes portrayed sadistic sex and sexualviolence’ following the 2012 consultation. [7] Again, if that is the case, no further policy change regarding images of sexual violence ought to be necessary.

Moreover, whereas the 2012 consultation was contextualised by an unusually high number of rejections, the most recent BBFC annual reports indicate that the current situation is entirely different. The ongoing 2018 BBFC consultation exercise focused on 15-certificate films. This emphasis is partially explained by the BBFC’s statistics for 2016 and 2017, which reveal that the largest number of film submissions were classified at 15 and very few were subject to any kind of cuts. Of the 401 15-certificate cinema releases in 2016, only one was cut. For comparison, of the 369 12A-certificated cinema releases in 2016, 187 were cut. [8] In 2017, three of the 392 15-certificate cinema releases were cut, compared with 42 of the 378 12A-certificate cinema releases. Of the 2,682 15-certificate video releases in 2016, none were cut. Again, for comparison, four of the 1,998 12-certificate video releases were cut and ten of the 364 18-certificate video releases were cut in 2016. In 2017, only four of the 2,307 15-certificate video releases were cut, compared with eight of the 331 18-certificate video releases. These statistics might suggest that the 15-certificate category is less problematic than others, given that barely any cuts were required to those releases. An alternative reading of the same data might suggest that further scrutiny is necessary given that a disproportionately low number of releases are subject to cuts in the 15-certificate category.

The data does not indicate what content was cut from any category. Much of the ‘strong’ violence that previously attracted an 18-certificate now sits within the BBFC’s 15-certificate classification. [9] The BBFC assert that they do not routinely cut films ‘on the grounds of violence alone’ and actively differentiate ‘between sexual and non-sexual violence’. [10] According to the lists aggregated from the BBFC website by Melon Farmers, in 2017 and up until the start of the 2018 consultation period’s second phase, no cuts were issued for sexual violence. Aside from two anomalous exceptions, [11] the bulk of cuts made to films during the period were category cuts (predominantly for violence, mainly at the 12/12A-certificate level). The other notable trend during the period is an exceptional number of films being cut for genuine animal violence. Indeed, Brotherhood of Blades II: The Infernal Battlefield (Yang Lu 2017) secured a 15-certificate for fabricated ‘strong bloody violence’ against humans, but 11 seconds of compulsory cuts were required to remove ‘scenes of animal cruelty (horses being tripped)’. [12] The 2017 re-release of Massacre in Dinosaur Valley (Michael E. Lemick 1985) by 88 Films was also cut by 13 seconds to remove authentic animal violence, while previous cuts for contrived violence (including sexual violence) were waived. [13]

Massacre in Dinosaur Valley (Michael E. Lemick 1985)

In this light, animal violence is a startling omission from the 2018 consultation’s second phase survey. The survey listed ‘issues that the BBFC take into account when giving age ratings to films’ and asked participants to select their ‘three most important areas of concern’. The categories listed were: language (bad/strong language; racist language; crude sexual language; other discriminatory language); sexual content (sexual violence/rape; explicit sexual scenes; sexualised behaviour in films watched by children under 15); violence (graphic violence; sadistic violence/torture; discriminatory violence [racist/homophobic]; domestic violence); horror (blood and gory scenes; supernatural scenes); drugs (illegal drug use; characters smoking tobacco); and other important issues (user specified). Although one could mention animal violence as an ‘other’ issue, one might have expected genuine animal cruelty to appear on the list given that it clearly led to numerous recent cuts (and fictional sexual violence has not). To reiterate, in the period leading up to the consultation, only two films were subject to category cuts for fictional sexual violence (to attain 12A classification), [14] while nine films were subject to compulsory cuts for genuine animal violence.

Until the BBFC releases a detailed report about the 2018 consultation’s first phase, the impetus for focusing on sexual violence at 15-certificate level will remain unclear. Yet, asking users to select areas of concern from a checklist in the second phase survey was inadequate inasmuch as it decontextualised each issue. Listing issues such as ‘sexual violence’ or ‘crude sexual language’ side-by-side implies that they are of equal concern to many participants. As an issue (stripped of context), ‘sexual violence’ is likely to feature on most participant’s lists, because sexual violence is a crime. In contrast, using ‘crude sexual language’ is not. Furthermore, images of ‘sexual violence’ do not exist in a vacuum; they are shaped by narrative context and tone. A movie about sexual coercion between teenagers, aimed at teenagers, might be best certified at 12A if the narrative has an overt socio-educational function. A horror film in which rape is seemingly employed for shock value is perhaps best classified at 18, although the explicitness and duration of the scene will also influence such a decision. The BBFC rightly account for context (including genre) in their classification decisions, so listing decontextualised ‘issues’ as if there are absolutes in the consultation survey is likely to yield misleading data.

The BBFC’s policy decisions also do not exist in a vacuum. The BBFC are not purely a consumer advisory organisation. They have authority to refuse classification and that capacity translates into economic power. The BBFC’s 2016 and 2017 statistics evince that the main bulk of films are classified in the 15-certificate category (the second largest classification category is 12A). Films in these categories attract the largest number of consumers with disposable income. Few films are classified — especially for cinema release — at 18-certificate level because that classification limits the audience-base and thus restricts a film’s commercial prospects. Many distributors accept category cuts to achieve 15 or 12A certification because doing so will maximise their potential audience share. If the BBFC were to place greater restrictions on films that feature images of sexual violence — classifying a greater number of those films at 18 rather than 15-certificate level, as journalists have proposed — studios are likely to pressure filmmakers into avoiding such depictions during production.

One’s response to the latter depends on which values one prioritises. For some, the situation would be loathsome because filmmakers are artists who should not have to compromise creative freedom for commerciality’s sake. For others, more restrictive classification conditions would encourage filmmakers to reflect upon and very carefully justify their use of sexual violence and so fewer filmmakers would be tempted to use sexual violence primarily to shock. This view suggests that sexual violence is a grave matter in real life and so should always also be treated with reverence in fiction. Others may object to that appraisal because fictional representations and real-world events are distinct from one another. Furthermore, restricting cultural, fictional representations of sexual violence may be objectionable because such a restriction may detrimentally impact broader cultural discourse. The silence and stigma that has surrounded real-world sexual violence is currently being countered by open, public discussion of the issue. The #MeToo campaign is illustrative of such discussion. This public discourse may come to be reflected in a wider array of sophisticated filmic ruminations on sexual violence. Ghettoising representations of sexual violence into an ‘adults only’ classification category may formally support the notion that sexual violence is too controversial for open public discussion. Such classification implies that under-18s ought to be shielded from encountering sexual violence but, since the BBFC’s remit only refers to cultural representations, such restriction would signal that the subject matter itself is unsuitable for young people. The latter does not appear to be a useful strategy for protecting young people from real-world sexual violence.

These positions are complex and require more detailed negotiation than can be offered here. By way of conclusion however, I underscore two points. Firstly, the BBFC’s 2018 consultation survey was reductive. The tick-box survey encourages the kind of oversimplification found in press responses. It also suggests that the second (large-scale) consultation phase was a tokenistic supplement to the first (small-scale) phase and will be used mainly to justify policy amendments that have already been decided upon. Secondly, the press’s (unfounded) proposal that ‘films with graphic rape scenes [are] to be rated 18’ oversimplifies a) the current level of public discourse regarding sexual violence, b) the conflicting values underpinning that discourse, c) the potential ramifications of such a policy and d) the complex considerations the BBFC face when classifying individual films. These responses suggest that the press, the BBFC and perhaps a public majority yearn for simple solutions to the problem of real-world sexual violence. However, failing to engage with representations of sexual violence in all their complexity distances us from that goal.


  1. Minutes from the 205th BBFC Board of Classification. Since writing this post, the BBFC have removed all mention of the consultation exercised from their website.
  2. See, for example, Emily Kent Smith. 2018. Films with sex attacks face automatic 18 rating. Daily Mail. 23 June; and Charles Hymas. 2018. Films with sexual violence will get 18 ratings after #MeToo backlash. The Daily Telegraph. 21 June.
  3. British Board of Film Classification Annual Report and Accounts 2012, 7.
  4. The only film that has been refused classification on the same basis subsequently is Hate Crime (James Cullen Bressack 2012), which was rejected in 2015.
  5. See Steve Jones. 2013. Torture Porn: Popular Horror After Saw. Basingstoke: Palgrave-Macmillan.
  6. Quoted in Smith.
  7. Smith.
  8. Of the 42 18-certificate cinema releases, none were cut. See British Board of Film Classification Annual Report and Accounts 2016.
  9. For example, action films such as Predator (John McTiernan 1987) and Marked for Death (Dwight H. Little 1990) were classified at 18 when initially released but have been released uncut with 15-certificates under contemporary guidelines. BBFC summaries published here and here.
  10. British Board of Film Classification Annual Report and Accounts 2017, 39.
  11. The two exceptions are Prank (Vincent Biron 2016), for which ‘cuts were required to remove sight of a young child in the same frame as pornographic images playing on a television screen’ (BBFC summary) and The Kitchen: World Chef Battle (Anton Fedotov 2017), for which a compulsory cut was ‘required to remove an incorrect classification symbol that does not reflect the BBFC classification of the work’ (BBFC summary). Both films were released in the UK with 15 certificates.
  12. Other films submitted in 2017-18 that were cut for animal violence include Adventure in Sahara (D. Ross Lederman 1938, BBFC summary), Brotherhood of Blades (Yang Lu 2014, BBFC summary); Cannibal Ferox (Umberto Lenzi 1981, BBFC summary); Ironmaster (Umberto Lenzi 1983, BBFC summary), Mountain of the Cannibal God (Sergio Martino 1978, BBFC summary); Navajo Joe (Sergio Corbucci 1966, BBFC summary) and The Planter’s Wife (Ken Annakin 1952, BBFC summary).
  13. See Massacre in Dinosaur Valley BBFC summary.
  14. The films are Motta Shiva Ketta Shiva (Sai Ramani 2017, BBFC summary) and Parava (Soubin Shahir 2017, BBFC summary).


Steve Jones is Head of Media in the Department of Social Sciences at Northumbria University, England, as well as Adjunct Research Professor in Law and Legal Studies at Carleton University, Ottawa. His research principally focuses on sex, violence, ethics and selfhood within horror and pornography. He is the author of Torture Porn: Popular Horror After Saw (2013) and the co-editor of Zombies and Sexuality. His work has been published in Feminist Media StudiesSexuality & CultureSexualitiesPorn Studies and Film-Philosophy. Her is also on the editorial board of Porn Studies. For more information, please visit / @DrSteve_Jones

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