USK: How to Avoid Trouble with Germany's Minor Protection as a Games Exhibitor

Anyone exhibiting at games trade fairs in Germany must comply with the country's youth protection law. Those who are not familiar with the law can be in for a surprise if their booth does not meet the standards. Marek Brunner of the Entertainment Software Self-Regulation Body (USK) explains in an interview how exhibitors can have their stands rated before the start of the fair, what it takes - and who doesn't have to be rated at all.

GamesMarkt: Do you rate all trade fairs with games exhibitors in Germany (e.g. Polaris, Dokomi, caggtus) according to the same criteria? Or do particularly strict inspection rules apply to gamescom because of its size?

Marek Brunner: In general, the provisions of the German Protection of Young Persons Act (Jugendschutzgesetz) apply to all trade fairs to which children and minors have access. Only games or video material with an age rating of "USK 0" or "USK 6" may be shown publicly. Exhibitors are responsible for ensuring that their stands and presentations comply with the provisions of the German Protection of Young Persons Act. The responsible local authorities will monitor Compliance with these regulations during the exhibition. Failure to do so may result in fines or even the stand's closure. Fairs such as MAG-C, Polaris, gamescom, and Dreamhack have different youth protection policies and special agreements with the local authorities. For example, USK 12 content may be publicly displayed at these shows, but children under 12 cannot play the USK 12 games themselves. At these fairs, visitors come specifically for a gaming event, and a parent or guardian accompanies children under 12, so there is a little more leeway.

How do timing and organisation of the rating for trade fair appearances work? Do the exhibitors contact you directly or does the fair organise a channel for them?

Exhibitors usually receive all the necessary information on child protection regulations with their exhibitor documents. First-time exhibitors are particularly sensitized and obtain additional information. The USK works closely with the organizers to ensure that all exhibitors have access to this information. Our cooperation intensifies in the months leading up to the trade fairs. For major events such as gamescom, the USK also sends email notifications to all exhibitors who have participated in previous years. We also provide a central exhibition page on our website with all the general information for exhibitors. For gamescom, the most significant event for the gaming community, we have set up a page visited by many exhibitors and summarises everything worth knowing. The organizers also play an essential role, reminding exhibitors of their obligations through emails, tickers, and deadline checklists. However, exhibitors must participate and set organizational priorities to get the correct rating. It is up to them to use the information and contact the USK in good time to comply with the regulations and avoid being subject to severe sanctions on site.

Will only the games shown on the stands be evaluated or are other factors rated as well?

As the games industry's self-regulatory body, our primary role is to monitor all content presented at the show, such as trailers, games, and demos. We also help with all issues relating to the protection of minors, such as stand design or the selection of artwork at the event.

Do all booths and games at the fair have to be rated?

No. Well-known games and displays that have been USK-rated for years do not need to be re-rated. Stands without games or those showing only hardware or corporate identity trailers need not be reviewed. If an exhibitor offers games specifically intended for adults only, they also do not need to be submitted to the USK to be assessed. Per the German Protection of Young Persons Act, these games remain unlabelled and may only be available to adults. In practice, this means that the design of the stand must ensure that such material is not visible to under-age visitors, for example, by providing separate rooms, monitors that face away from the stand, and privacy shields. In addition, access control by the exhibitor's stand personnel must be ensured. In addition, access control by the exhibitor's stand staff must be provided. These games may not carry a USK 18 rating but only a generic 18+ rating or the words "adults only". In these cases, however, there is no indexing protection provided by a USK age rating in accordance with the German Youth Protection Act.

How are collective stands rated, for example the big Indie Arena Booth at gamescom? Do these submit the games collectively?

A contact person usually collects all the information about the content to be rated. We then receive this list and access to all materials, including keys and anything else needed. If everything meets the requirements, a single age rating is assigned to the entire booth. Vendors also have the option to group titles by age, as is common in Indie Arenas. For example, games with a 12+ age rating can form their category. This way, games with a USK-6 rating do not have to "suffer" from the higher rating of the entire booth.

How do you control ratings during the fair? Do you go (with police or security) to all the stands that were not checked before the fair?

During the trade fair, the local authorities monitor compliance with the regulations; for gamescom, this is the Public Order Office of the City of Cologne. As USK, we work closely with the relevant public order office. There is a joint tour on the trade fair's opening day. We look at all the stands and check that all content is correctly labeled and that only approved content is accessible.

Do you do last-minute rating at the trade fair as well?

At the fair itself, we don't give any ratings further. The process is too complex. We do not have the staff or time to do it on-site. Stands and games that are not rated must comply with the laws for unrated games. This means that they must not be made available to children and minors.

**Can you tell us some known problems with exhibitors who did not have their appearance checked in advance? **

Most of the problems occur with international first-time exhibitors who are not sufficiently aware of or do not consider the German regulations on the protection of minors. Therefore, we are working with Koelnmesse when it comes to gamescom to reach these exhibitors with all relevant information.

What do you recommend to exhibitors who want to make sure that their next trade fair appearance is not only approved for 18+?

There are exhibitors out there who want an 18 rating for their next horror game - so there are no younger people wanted on the stand here in any case. For everyone else, the rule is to submit content to the USK for classification in good time. The USK is, of course, always available to answer any queries.

Further Information:

General Information for Fairs & Events in Germany

Special Infosheet for gamescom

Contacts to USK:

Marek Brunner (Chief of Testing & ARAC) and Lara Schulze (Testing): testbereich@usk.de

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