TV CONTENT RATING AND PROTECTION OF CHILDREN
– ANALYSIS OF NATIONAL BROADCASTERS’ PROGRAMMES
- Summary -
Belgrade, November 2013
REGULATORY FRAMEWORK
In the European Audiovisual Media Services Directive (2010), it is stressed, among other
things, that it is necessary to safeguard the public interest, to ensure the right to
information and to protect minors from harmful content, thus providing a framework in
which a diversity of media content should be developed. In line with the need to protect
children from harmful content, the practice of having protected slots on radio and
television has been introduced, meaning the prohibition of broadcasting content aimed at
persons older than 16, or 18 before evening or night-time hours.
For the same reason, content rating systems are also being developed and distributed to
various communication channels, so that broadcasters can inform the audience - parents about media content that might be harmful to children of various ages by displaying
appropriate rating information.
A rating system involves establishing criteria and adequately informing the public about
the rating information used. Based on unambiguous information about the content,
audiences can choose whether to view a programme or not, and not only when it is a matter
of content harmful to children, but also upsetting scenes, vulgar speech, and scenes of
violence and sex. The responsibility of the media and their role in informing the public is an
important part of spreading media literacy, because in that way audiences (in this case,
parents) are asked to take an active role.
In its recommendations of 2008 (Guidelines for Broadcasting Regulation), in addition to the
above-mentioned, UNESCO also underlined the need to protect human dignity (Articles
7.28 – 7.32) and to protect persons from upsetting visual and light effects (e.g. viewers
suffering from photosensitive epilepsy).
In Serbia, most of these principles has been recognised and stated in the Broadcasting Act
(Article 191, Article 104, paragraph 3, Article 68, paragraphs 1 and 52); Public Information
Broadcasting Act (“Official Gazette of the Republic of Serbia“, nos. 42/2002, 97/2004, 76/2005 – state law,
62/2006, 85/2006, 85/2006 – corrections and 41/2009), Article 19:
- the Agency ensures that minors are protected and that personal dignity is respected in programmes
broadcast on radio and TV, regarding which it issues general binding instructions.
- in particular, the Agency ensures that programmes that may be harmful to the physical, mental or moral
development of minors are not available on radio or television, except when the time of broadcasting or
technical protection ensure that minors are not, as a rule, able to see or hear such programmes.
- Showing programmes seriously impairing the physical, mental or moral development of minors is prohibited.
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Broadcasting Act (“Official Gazette of the Republic of Serbia“, nos. 42/2002, 97/2004, 76/2005 – state law,
62/2006, 85/2006, 85/2006 – correction and 41/2009), Article 68:
When broadcasting their programmes, all broadcasters shall, as part of their programme concept, comply with
the following standards regarding programme content:
1) Applying international and national standards, they shall ensure the production and broadcast of highquality programmes both from the technical aspect and from the aspect of programme content;
5) They shall not broadcast programmes the content of which may harm the physical, mental or moral
development of children and young people, but shall clearly rate such programmes and if they choose to
broadcast them, they shall do so only between the hours of 12am (midnight) and 6am;
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Act (Article 413), and General Binding Instructions on Broadcaster Conduct (Broadcaster
Code of Conduct) of the Republican Broadcasting Agency, responsible for protecting minors
and personal dignity (items 3 and 4).
The Broadcaster Code of Conduct, which is a set of binding instructions, contains the
Instructions Related to the Protection of Children and Young People and the General
Binding Instructions on Broadcaster Conduct regarding the broadcast of programme content
that may be harmful to the physical, mental or moral development of minors.
METHODOLOGICAL APPROACH
The methods used consist of content analysis, comparative analysis and research through
focus groups. .
Content analysis covered the programmes broadcast by five TV companies with
nationwide frequencies, i.e. six TV channels in total (RTS1, RTS 2, TV B92, TV Prva, TV
Pink, TV Happy), over a period of six months (1 January - 30 June 2013). Films, TV series,
reality shows, as well as entertainment, documentary, scientific, educational, cultural, artistic
and musical programmes and children’s programmes were analysed. News programmes,
which are not subject to content rating, were not included in the analysis.
The units of analysis were programme type, broadcasting slot, and age rating of the
programme.
The analysis was conducted on the basis of a database created during the twenty-four-hour
regular monitoring of broadcasters with a national licence, carried out by the Monitoring
Department of the Republican Broadcasting Agency.
Existing rating practice was analysed in order to establish the amount of certain types of
programme, rated programmes, and broadcasting slots of rated programmes.
The starting point of the research was the idea of the need for the existence of “protected
broadcasting slots“, on the assumption that programmes with high ratings (16 and 18)
should be broadcast in late evening and night-time hours. Programmes rated as “16” are to
be broadcast between the hours of 9pm and 6am, and programmes rated as “18” (as
envisaged by the RBA Code) are to be broadcast between the hours of 12am (midnight)
and 6am.
Public Information Act, (“Official Gazette of the Republic of Serbia“, nos.43/2003, 61/2005, 71/2009,
89/2010 – decision issued by the Constitutional Court and no. 41/2011 – decision issued by the Constitutional
Court) Article 41:
- In order to protect the rights of minors, special attention must be paid in public media that the content of public
media and their manner of distribution shall not harm the moral, intellectual, emotional or social development
of minors.
- The content of public media that could harm the development of minors, in the sense of paragraph 1 of this
Article, must be clearly and visibly rated as such in advance and distributed in a form least likely to be used
by a minor.
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As part of the analysis, examples of programmes and shows were singled out and their
content was described in order to point out specific dilemmas and explain recommendations
regarding content rating.
Reality and pseudo-reality programmes, which are present in some form on all the TV
channels, were recognised as a separate programme category, after content analysis made
this evident due to their frequency, variety of format and rating information.
The content analysis findings related to feature film programmes were supplemented with
detailed information and a comparative analysis of film rating indication, in order to gain
insight into the differences and similarities and the methods and logic of film rating indication
– types of rating relevant to potentially harmful and unsuitable content – both in Serbia and
in other countries.
On a sample of 1,670 films, broadcast for the first time in the period from 1 January to 30
June 2013, and based on the available data, film rating indicators were compared to the
original ratings and those assigned in other countries. The international Internet Movie
Database (IMDb) was used as the data source. The sample also included domesticallymade films, which could not be subjected to the comparative rating indicator analysis, and
their rates were therefore analysed in more detail by comparing them to similar content.
Based on the data obtained during the research, focus groups were organised with
parents of children aged from 10 to 17 in five cities in Serbia (Belgrade, Novi Sad, Niš,
Subotica, Čačak). Each focus group was attended by 6 to 10 participants. Discussions
lasted an hour and a half on average, and the guide for focus group work was prepared on
the basis of results obtained through the programme analysis. The goal of this part of the
research was to examine in more detail the attitudes and opinions of parents on content
rating (especially of content which they deemed as inappropriate for their children), as well
as on the need, effectiveness and potential of TV content rating in child protection. The
parents also gave their opinions on possible forms of content rating, as regards visual and
content solutions for displaying rating information. During the focus groups, the parents
were also provided with examples of content aimed at various ages and broadcast on the
analysed TV channels – with an emphasis on films, TV series, and reality shows – mainly in
afternoon and early-evening hours.
The recommendations have been formulated on the basis of an analysis of the available
data, of adequate technical literature and practice in other countries, in cooperation with an
expert in developmental psychology.
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MAIN FINDINGS
- Characteristics, structure and rating of TV programmes
The Public Broadcasting Service RTS (consisting of two channels), offers an ample
schedule of children’s, cultural, artistic, documentary, scientific and educational
programmes, broadcast during both day and night. As in the case of other TV companies, it
was noted that programmes not recommended for children under the age 16 (mainly TV
series) are usually reprised in daytime slots.
However, it is clearly evident on the RTS channels that the entire schedule structure
complies with the provisions related to child protection and that specific rules are respected
when rating programme content. Unsuitable content is either not broadcast or is moved to
late-evening hours.
It was also noted that programmes aimed at audiences of all ages – scientific and
educational, cultural and artistic, musical and documentary – are very often broadcast after
midnight.
Programmes of commercial TV channels
It is a characteristic of TV Pink to broadcast the largest number of reality formats, which
were frequently shown in daytime slots although some of them are unsuitable for all-day
broadcasting. Reality and pseudo-reality programmes were mainly unrated, except for those
entitled DNK [DNA] and Farma [The Farm], which was rated “12“, and Trenutak istine
[Moment of Truth] which was rated “15“. The reality show Farma was totally unrated 15
times. Also, in the majority of cases, neither the “12“rating nor the broadcasting slot were
appropriate to the broadcast content (which included alcohol use and talk of alcohol,
offensive and vulgar vocabulary, fights, arguments, insults, and sexual activity by the
participants).
The show Trenutak istine was rated but its reprise slot was inappropriate. It was repeated
around noon, at a time when children are at home and when they can thus have the
possibility of hearing stories from which they can draw wrong conclusions about violence
and serious criminal offences that go unpunished.
Although the indicators “12“, “15“ and “18“ were used when rating the programmes, the
pseudo-reality format Preljubnici [Adulterers] was the only show rated “16“. However, this
did not result in its broadcasting slot being moved to the nighttime. Considering the topics
dealt with on this programme and the manner in which these are handled, this show was
also inadequately rated and broadcast in an inappropriate slot.
The entire entertainment programme of TV Pink bore the rating”for all ages”. Studio
recordings and music shows were not rated, except for the show Grandovo narodno veselje
[Grand popular celebration] which was rated “12“.
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The analysis has shown that TV Pink programmes abound in reality programmes. There are
no children’s programmes on this channel.
Entertainment shows are dominant on TV Prva – serials, films and entertainment
programmes. Of the entertainment programmes, only the show Veče sa Ivanom
Ivanovićem [An Evening with Ivan Ivanović] was rated (14).
Taking into account their content, the serials broadcast by TV Prva were mostly rated in an
appropriate manner.
TV Happy broadcasts studio-recorded entertainment programmes and music shows that
are not age-rated and are thus aimed at persons of all ages, but it does rate reality and
pseudo-reality shows. This channel offers a somewhat specific film programme, consisting
largely of domestically-made films and westerns, and after midnight it broadcasts erotic
films.
TV Happy had the largest amount of unrated and inadequately-rated content and also
broadcast 33 films without a title. The analysis shows that this broadcaster incorrectly
specifies the age limits for which its programmes are suitable. Some serials have episodes
differently rated – e.g. when broadcast for the first time, a serial was rated “12“ or “14“, and
then in the reprise slot was not rated at all.
TV B92 broadcasts a variety of content, but during the observation period it was also
broadcasting the reality show Veliki brat [Big Brother], which has plenty of scenes
unsuitable for showing before midnight.
This is the only TV channel that rated all its films. However, there were no films suitable for
all ages, except for one reprise that remained unrated (though during its first broadcast, the
film was rated). TV B92 is also the only channel using the full range of rating indicators for
films (12, 13, 14, 15, 16, 17, and 18).
The documentary programme of TV B92 was usually broadcast in the early-morning hours
and during the night. It was intended for all ages and more varied than children’s
programmes.
The scientific and educational programmes were also aimed at all ages and broadcast
usually during the night and early in the morning.
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In the course of the analysis period, TV channels with a nationwide frequency
broadcast a total of 39 different reality shows.
Broadcaster
RTS (4)
Name of programme
Ja imam talenat [I’ve got talent]
I ja imam talenat [I’ve also got talent]
Šljivik [Plum orchard]
Vreme je za bebe [It’s time for a baby]
Rating
No rating
Skrivena kamera [Candid camers]
Dome, slatki dome [Home, sweet home]
Veliki Brat [Big Brother]
No rating
No rating and 14
No rating (8 times),
14 (10am-7pm),
15 (7pm-1/2am),
18 (12am-2am)
TV B92 (5)
TV PRVA (8)
Broadcaster
TV PINK (14)
TV HAPPY (8)
Nepobedivi banzuke [Unbeatable Banzuke]
Nindža ratnici [Ninja warriors]
16
17
Skrivena kamera [Candid camera]
Prvi glas Srbije [Top voice of Serbia] Finale
Paklena kuhinja [Kitchen from Hell]
Radna akcija [On the job]
Dođi na večeru [Come to supper]
Domaćine, oženi se! [Host, get wed!]
Sami u tami [Alone in the dark]
Porodične tajne [Family secrets]
No rating
No rating
No rating
No rating
No rating
No rating
16
16
Name of programme
Skrivena kamera [Candid camera]
Lutajuća kamera [Roving camera]
Paparaco, lov na poznate (Grand Production)
[Paparazzo, hunt the celebs]
Zvezde Granda [Stars of Grand]
Moja velika svadba [My big wedding]
Sve za ljubav[All for love]
Kuvanje i muvanje [Cooking and fooling around]
Srpska posla (VIP estrada) [Serb job (VIP show]
Neobjavljene priče [Unpublished stories]
Sudnica [Court-room]
DNK [DNA]
Farma [The farm]
Trenutak istine [Moment of truth]
Preljubnici [Adulterers]
Rating
No rating
No rating
Pozajmi mi auto [Lend me a car]
VIP 24
Ljubavni signali [Love signals]
Laka lova [Easy money]
Dokaz ljubavi [Proof of love]
12 srca [12 hearts] (Spanish)
Sudbine [Destinies]
Luda kuća [Mad house]
No rating
No rating
No rating
No rating
No rating
16
16
16
No rating
No rating
No rating
No rating
No rating
No rating
No rating
No rating
12
No rating (15 times), 12
15
16
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The analysis findings show that:
1. Broadcasters do not strive to structure their programmes in line with rating
indicators. Thus, for example, programmes rated “14“, “15“ and “16“ (reality
shows, reprises of films and serials) were being broadcast throughout the day,
while some programmes suitable for all ages were broadcast during the night.
2. There is inconsistency in rating programmes with the same or similar contents on
one and the same channel, or the same or similar programmes are differently
rated on different channels.
For example, the film Bure baruta [Cabaret Balkan] was not rated on TV Happy
and was broadcast at 7.28pm, while on RTS Channel 1 it was rated “16” and
broadcast at 9pm.
3. Programmes containing scenes of violence in a comical context (rough behaviour
similar to that seen in cartoons, and mild vulgarities) or sexually-coloured
language or promoting stereotypes are often unrated, implying that they are
suitable for all ages – for example, romantic and other comedies made in the
USA, usually rated in the original as suitable for ages over 12.
4. There is a great difference in content rated in the same way, even by the same
broadcaster. For example, the rating “12” was attributed to a wide range of
programmes – from foreign films and soap operas and domestically-made films
and serials to reality shows.
5. The rating “14” was used by all the TV companies except for TV Pink. According
to the findings of the comparative analysis of feature film programme, this
indicator is used to rate all kinds of content – even those that could be rated “12”
and those that are actually closer to “16”, and even (rarely) with “18”. The rating
“18” was usually applied to horror and erotic films.
6. The criteria for rating domestically-made films and serials are insufficiently clear.
For example, the serial Folk broadcast by TV Prva is rated “12“, while the serial
Montevideo, Bog te video [Montevideo, God bless you!] shown on RTS is rated
“14“.
7. The reality shows Veliki Brat4 Farma and Trenutak istine, as well as pseudoreality formats such as Luda kuća, Preljubnici, Porodične tajne, Neobjavljene
priče and Sudbine were, in view of their respective concepts, language used and
scenes shown, rated inadequately and broadcast in inappropriate slots.
4
For a translation of this and other programme titles in this paragraph, see tables above.
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The findings of the focus groups with parents, showed that:
1. The biggest problem lies in the entertainment content broadcast by commercial
channels, as well as the promotion of consumer culture and celebrities as role
models.
2. There is greater tolerance towards domestically-made TV serials when it comes to
content rating.
3. It is necessary to match the time of broadcasting with the type of programme being
broadcast.
4. The best solution for the majority of unsuitable content is to move its time of
broadcasting to around 9 or 10pm, and to move that rated “18“ to after-midnight slots.
5. Children need to be offered a wider choice of programme (parents think that children
would not watch a poor-quality programme if they had a bigger choice of high-quality
content, especially that aimed at their age and interests, and thus they would be
better protected from unsuitable content).
6. There is a low level of tolerance to violence on TV programmes . Differences were
noted between types and intensity of violence, and it is believed that the effect of
scenes of violence depends on the gender of the child.
7. It is thought that violence presented with a dose of humour may mitigate the negative
effect, depending on the “full picture”, i.e. the context. The rating indicator should
depend on the level and form of violence shown.
8. It is necessary to make some kind of preparation for watching a film – a conversation
immediately before the film is important, as is an introduction to what is about to be
shown, even when it is shown in the evening, which used to be the practice on
television, especially when it is a question of films that may be “difficult“ for children,
as well as for viewers in general.
9. It is inappropriate to show drug abuse in any form. Such content, if impossible to
abolish, should not be broadcast before late evening and should be rated “18”.
10. The over-abundance of reality and pseudo-reality shows is one of the reasons why
children (and others) watch them, and thus it is necessary to limit their broadcast or
to move their times of broadcast to later, evening hours. It is also proposed that such
shows be moved to a special channel, which would ensure a certain level of control.
11. (Pseudo-)reality shows which reward (with money or “five-minutes “of fame) types of
behaviour that may harm children’s development and convey to them wrong
messages about violence, sex, interpersonal relationships, life, promiscuity, alcohol
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and drug abuse, such as the show Trenutak istine5 and the pseudo-reality shows
Preljubnici and Luda kuća (and other shows with similar concepts) should be rated
“18” and not be broadcast before midnight.
12. Insulting speech (verbal violence) is, to parents, more noticeable, and inappropriate
in reality shows. Insults are a great problem because they imply certain attitudes
towards other persons, so a rating of “16“ or higher is proposed.
13. Sex, sexuality and sex talk may be rated depending on the context and level of
explicitness if it is present in fictional programmes, but showing of sex or sexual
activity in reality shows should be prohibited.
14. There is a similar attitude to violence, fights and physical attacks which are deemed
to be totally unacceptable in reality shows.
15. Content rating without introducing and observing “protected slots“ does not contribute
much towards protecting children from harmful content. It is proposed that the
broadcast times of shows with inappropriate content be moved to later-evening and
night hours. Announcements or trailers should be subject to the same criteria as the
shows they advertise, i.e. they should be given the same ratings and be broadcast
during slots envisaged for such content.
RECOMMENDATIONS
Analysis of programmes and discussions with parents have resulted in the following
recommendations which could contribute to better protection of children from programme
content that is inappropriate for them:
A) Defining clear criteria on the basis of which programme content would be rated.
This recommendation is related to the fact that content is frequently unrated and/or rated
inadequately.
B) Introducing the rating indicator “PAL“ – “parental advisory“ – indicating the need for an
adult to be present during the viewing of a programme rated in this way.
C) Rating information should be shown all the time during the broadcast of a
programme regardless of the age indicator (it is currently done only in case of an “18”
rating),
D) Additional warnings before the broadcasting of content with explicit scenes of
violence and sex, brutal scenes, strong visual or light effects, rapid succession of frames,
and the like. In other countries, such programmes are rated “R“ (Restricted in the USA) – for
scenes of explicit sex, violence, abuse of psychoactive substances, etc – or are
5
see note 4 above
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accompanied by audio and visual (textual) warnings.
E) Trailers for films, reality shows, etc. should carry a rating indicator matching their
content.
F) When rating content, the context should also be taken into account– positive role
models and messages, instructive elements, etc.
G) Introducing “protected slots” for each age group. Rated content should be scheduled in
slots based on its rating. Content rated with lower-age indicators should be broadcast at
times when it may be viewed by the audiences for which it was intended.
H) Later (evening and night) slots, outside the “protected slot“, and ratings for
programme content showing alcohol abuse, inappropriate language, fights, insults, sexual
activity, etc.
I) Eventual introduction of the rating “10“, in addition to the existing age categories
(“suitable for all ages“, “12“, “14“, “16“ and “18“).
J) Content differentiation between “artistic” films and films of other genres which also
contain scenes of violence, sex and inappropriate behaviour, and carry the same rating.
Besides indicating that they show potentially unsuitable content and the need for an adult
presence, one of the possible solutions is to provide information on the film genre (also
applicable to other types of fictional programmes).
K) Informing the public through existing information channels (TV channels themselves,
print media, teletext, etc.) regarding the criteria and manner of rating TV programmes.
L) Publishing rating information on programme content in announcements of TV
programmes (print media, teletext).
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