An Open Letter to the Video Standards Council

With Omega Labyrinth Z being the first game to be refused classification in the UK for a decade — the last was Rockstar’s ultra-violent Manhunt 2 — there has been a lot of discussion surrounding the title.

With that in mind, I felt it important to express my own feelings on the matter directly to the Video Standards Council (VSC), the body responsible for refusing to allow the game to be sold in the United Kingdom, despite it already having successfully attained a PEGI 18 rating elsewhere in Europe.

If you feel similarly, I encourage you to reach out to the VSC yourself using the contact details on their website. I shouldn’t have to say this, but I will anyway: if you choose to do so, please keep your messages polite and respectful, whatever you may think of the decision. And whether or not anything changes as a result of feedback from consumers like this, we can at least say we tried to get our voices heard.

The letter I sent directly to the VSC follows after the jump.

Omega Labyrinth Z

Dear Sir/Madam,

It was with some dismay that I heard of the VSC’s decision to refuse classification in the UK for the PlayStation 4 and Vita game Omega Labyrinth Z, and I write to express my disappointment and concern over the matter.

Omega Labyrinth Z is a Japanese video game developed by Matrix Software and published in its native territory by D3 Publisher. The localisation and publishing in the English-speaking world is handled by PQube, a company based in Letchworth and Bristol in the UK. PQube has, to date, brought a wide variety of Asian interactive entertainment properties to English-speaking locales as well as publishing titles from small, independent developers, and has proven itself repeatedly to be a company that respects both its customers and the developers of the works on which its localisations are based.

Gal*Gun Double Peace

Prior to Omega Labyrinth Z, PQube had published a variety of localised Japanese games featuring mature content without incident. Of particular note are the games in the Gal*Gun series, of which the sequel is shortly to be released in the West (and which, despite featuring similarly provocative themes to Omega Labyrinth Z in places, has not been refused classification), Korean horror game White Day, and visual novel Chaos;Child. All of these feature both mature themes and Eastern- or anime-style artwork, as also seen in Omega Labyrinth Z, yet have not been refused classification on the grounds that there will be “leakage” to those too young to play the game, as your representative “Gianni” noted in conversation with Operation Rainfall recently.

The primary objection that enthusiasts of Japanese gaming such as myself have with the VSC’s decision in this case is that it appears to be inconsistent with instances such as the aforementioned, as well as a tacit admission that the legally enforceable PEGI ratings are apparently insufficient to prevent minors from accessing mature content. PQube intends to release Omega Labyrinth Z throughout Europe with a PEGI 18 rating, which would make it illegal for UK retailers to supply it to those under the age of 18, as well as making it abundantly clear to consumers at a simple glance that the game in question is not suitable for children. Parental control features in place on all modern consoles also allow parents to block access to inappropriate material, even if a minor manages to come into possession of it.

Omega Labyrinth Z

The VSC’s decision to “overrule” this rating for the UK suggests both a lack of confidence in the rating system it is an administrator of — in which case I would urge a review of how it is handled, perhaps through the addition of an “adults-only” rating similar to the BBFC’s R-18 classification, as I explain in more detail in this article — and a lack of respect for consumers to be able to make informed decisions as to which content they wish to engage with.

Like many games of Japanese origin, Omega Labyrinth Z is a relatively small-scale, niche-interest release that is unlikely to have been noticed by the mainstream and general games-buying public at all were it not for the media coverage the VSC’s decision has attracted. As such, it is extremely unlikely that, as Gianni suggests in their conversation with Operation Rainfall, the game will accidentally “leak” into the hands of those for whom it is unsuitable, since it’s not the sort of game many will pick up purely on a whim. By extension, refusing classification of the game in the UK and preventing it from being sold is not actually “protecting” anyone; all it is doing is punishing legitimate consumers over the age of 18 who wish to enjoy the game in their native language rather than importing a Japanese copy and, in most cases, being unable to understand the dialogue and story.

Grand Theft Auto V

The other issue here is the apparent double standard on display with regard to content that passes through classification unscathed, and that which falls foul of the censors as this one has done. A significant majority of the top-selling games each year have PEGI 18 ratings, and feature explicit violent scenes as well as, in some cases, sexual content. The consistently popular Grand Theft Auto series, for example, features graphic scenes of torture, drug use and the ability to engage in wanton interactive acts of violence and terrorism whenever the player sees fit, yet this — quite rightly — does not get refused classification on the grounds that people for whom it is unsuitable might get hold of it. In the case of Grand Theft Auto, the consumers are trusted to keep the game out of the hands of children, the retailers are trusted to only sell it to those who have proven they are old enough, and everyone comes away happy.

And yet with Omega Labyrinth Z, a game which is significantly lighter in tone than any of the Western 18-rated games which line the store shelves on a yearly basis, we are expected to believe that there is suddenly a risk that it will fall into the wrong hands and will do “harm” to those in their formative years? Leaving aside the already discussed lack of trust for consumers, I believe there is far less scope for lasting “harm” in a game with sexually provocative content — sexually provocative content that is both non-explicit and not the central focus of the game, I might add — than a game which places violent behaviour front and centre as the primary means of interacting with the world and its inhabitants.

Omega Labyrinth Z

The primary point of concern with Omega Labyrinth Z appears to be the misconception that its colourful anime-style artwork makes it appealing to under-18s and that, in turn, its sexualised content would cause under-18s would develop an “inappropriate” view on sexuality. In response to this, I would simply point out that Japanese popular media, including anime, manga, video games and illustrated light novels, has always featured artwork of this style (albeit with some evolution over the decades), and has always run the gamut from family-friendly entertainment to material that is emphatically intended only for adults.

Art style alone is not a convincing argument of the VSC’s case that Omega Labyrinth Z has been deliberately designed to appeal to under-18s. And the over-18s for whom the game is intended should be trusted to distinguish fantasy from reality, meaning that the clearly fantastic depictions of sexual scenes in the game are simply that — fantasies, which no-one in full possession of their mental faculties will go out and re-enact in society at large.

Criminal Girls

I urge you to reconsider your decision on Omega Labyrinth Z. My website MoeGamer ( specialises in the coverage of niche-interest localised Japanese entertainment such as this, and my articles have clearly demonstrated on numerous occasions that there is great value in a variety of games with provocative content; I urge you to inform yourself on some of these examples that have previously passed by the VSC without issue.

NIS America’s Criminal Girls, for example, uses its non-explicit sexual sadomasochism scenes to reinforce its narrative’s core themes of trust, for example. Aquaplus, Sting and Atlus’ Dungeon Travelers 2 makes use of imagery themed around nudity to reflect the ideas of coming to mutual understanding. Marvelous’ Senran Kagura series features an enormous cast of young women who are depicted as coming to terms with a variety of relatable issues for young women — including sexuality. And, although unrated by organisations such as the ESRB, PEGI and the VSC due to their position as PC games without a retail presence, Frontwing’s visual novels in the Grisaia series demonstrate that sexual themes can form an important part of an interactive narrative.

Senran Kagura: Estival Versus

Finally, I also feel it is important to note that the UK is a significant consumer in the global industry of interactive entertainment, not only because a significant proportion of high-profile developers and publishers started (and are still based) here, but also because we are an English-speaking territory of not-inconsiderable size and influence. To deny a company such as PQube the opportunity to sell a product it has worked on in its own native territory when said native territory is proven to be a significant market… well, it just doesn’t seem very supportive of British businesses and values.

I urge you to re-open dialogue with PQube over the matter of getting Omega Labyrinth Z classified for sale in the United Kingdom, because I fear a title like this being made unavailable for sale sets an uncomfortable precedent. The PEGI ratings and the fact they are legally enforceable should be more than enough to protect those for whom this game is not intended from getting hold of it. And consumers who would be of legal age to purchase it should be trusted to make the correct, informed decisions for themselves — and, where applicable, their families.

Thank you for your time.

Yours faithfully,

Pete Davison

8 thoughts on “An Open Letter to the Video Standards Council”

  1. VSC responded pretty much as expected:

    Hello Mr Davidson [sic],

    Thank you for your comments concerning the above game. They have been duly noted, but you should understand that the decision is final. PQube did have the opportunity to appeal against the decision, but did not wish to do so.

    Best wishes,

    The VSC Rating Board

    Despite this response being entirely what I expected, I think it’s still worth speaking up on this, if only with future releases in mind. It’s a shame PQube chose not to fight a little harder, but I can entirely understand why.

    As for me, I’ll be importing Omega Labyrinth Z from elsewhere when it becomes available.

    Liked by 2 people

      1. Yeah, I imagine I’m not the first to post such a message. The Operation Rainfall link in the piece got an actual human(ish) response from the same person who supposedly replied to me, so hopefully someone is actually reading them.

        We’ll see, I guess. A UK release for this game is probably a lost cause at this point (and importing is easy anyway), but that doesn’t mean comments can’t be taken on board for future classification decisions.


  2. Well written mate, it show how much hipocrisy there is here in their decision and how much prejudice they have toward japanese media. Anime art style and related archetypes are always portrayed like this in these ecchi games, is nothing new and lots of anime are also released there in UK with the same ecchi innuendos.
    Normalizing a behaviour? Riducouls, there is no connection with reality at all since anime art is so stylized and far to rapresent real people, with this logic everything not politically correct or morally different in fictional media can ne unrated so banned using this normalization excuse.
    Last, the fact that someone under 18 can play the game is something you have difficult to believe when you read it from a rating organization, is like they said that their rating system is absolutely useless since people do whatever they want anyway. Pathetic.
    Thanks god that at least you uk fans can import the game without any issue.

    Liked by 2 people

  3. I will import the game, as will many others, so their censorship move is pointless. Interesting remark about not choosing to appeal. PQube said “The USK appeal we tried was rejected, other appeals would have yielded the same result so those decisions are final.”

    Liked by 1 person

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