China: SAPPRFT's New Administration Regime Over Mobile Games: What've Happened Since July?

Last Updated: 3 January 2017
Article by Tracey Tang

The third quarter in 2016 has been an extremely busy one for China mobile game industry, not only for the market practitioners such as game developers, publishers and operators, but also for the regulatory authority, China State Administration of Press, Publication, Radio, Film and Television ("SAPPRFT", "国家新闻出版广电总局"). This is because the Notice on the Administration of Publishing Services of Mobile Games ("Notice", 《关于移动游戏出版服务管理的通知》) which requires mobile games must be approved before being published took effect on July 1, 2016. This article intends to give a general overview on SAPPRFT's implementation of the Notice during Q 3 2016 and discuss certain issues on SAPPRFT's approval requirements.

Overview of SAPPRFT's Approvals of Mobile Games during Q3 2016

Since July, SAPPRFT has enormously increased its efficiency of reviewing and approving mobile games. According to the information released by SAPPRFT, it granted approvals to 110, 445 and 513 mobile games respectively in July, August and September 2016. Statistically speaking, it signifies a huge change in SAPPRFT's administration regime compared with that only around 400 mobile games were approved in the whole year of 2015. Though most game publishers or operators have busily engaged in the preparation of applications after the promulgation of the Notice, it still seemed unrealistic for them to complete the application filings of all existing games by the end of Q3, the grace period granted under the Notice. Therefore, in late September, SAPPRFT proactively extended such grace period to December 31, 2016. This means the Notice will be fully implemented and applicable to all mobile games—the newly released and those downloadable and in operation—after January 1, 2017.

Simple Games and Simplified Approval Process

It came as no surprise that a vast majority of mobile games approved in Q3 2016 was subject to a simplified approval process that, according to the Notice, is only applicable to any mobile game that meets all the following criteria ("Simple Game") (i) game copyright is owned by domestic individuals or entities, (ii) it does not contain any sensitive elements such as politics, military, ethnicity or religion, (iii) it has no storyline at all or only has very simple storyline, and (iv) it is in the genre of casual games including match-three, endless runner, top down shooter, board, puzzle, sports, music and etc. According to SAPPRFT's latest practice, such causal game genre has been expanded to include fish catching, coloring, ejection (such as pinball), placement and simple block building games as well.

In addition to the simplified application documents and shortened review period, SAPPRFT has recently facilitated the simplified process by launching an online application system where application information and documents can be easily submitted online, moreover, SAPPRFT's review and approval status are updated online on real time basis. After having taken these measures, SAPPRFT is expected to further enhance its work efficiency and approve more Simple Games in the fast track process, which may take around 15 business days.

Approval of Foreign Copyrighted Games

In contrast, SAPPRFT's procedure for reviewing and approving mobile games that do not meet the criteria of Simple Game ("Non Simple Games") remains unchanged, which is still quite complicated and time-consuming (4-6 months on average). This explains why only 10 out of more than 1000 approvals in Q3 are foreign copyrighted mobile games. The obvious mismatch between the number of approved foreign games and those currently alive in the APP Stores indicates a very tight deadline that many publishers or operators of foreign games must catch—if applications cannot be submitted before December 31, 2016, the game operations might be shut down.

It's particularly worth noting that SAPPRFT currently adopts a very broad interpretation of "foreign copyrighted game" that not only covers games developed by foreign developers but also include those developed by domestic parties based on storylines, characters or other content licensed by foreign content providers. In other words, as long as the game content is not entirely owned or controlled by domestic parties, such game would be regarded by SAPPRFT as a foreign copyrighted one and thus would be ineligible for the fast track process. In this connection, disguising a game licensed by foreign party as a "China-made" one (such as to register game software under a Chinese party's name) in order to take advantage of the simplified process does not seem a viable option.

Mobile Game Content Standard

SAPPRFT's examination of Non Simple Games has never been a formality. It involves the reviewers' full access and evaluation of all game content, including texts, storylines, plots, scenes, maps, characters, props, power-ups, in-app purchases, music, sound effects, functions, tasks, illustrations, in-game advertisements and etc. according to the applicable Mobile Game Content Standard ("Content Standard") and other relevant rules adopted by SAPPRFT. As far as 2016 version of Content Standard published by China Audio-Video and Digital Publishing Association is concerned, it consists of comprehensive criteria specifying what content must not contain in any mobile game with a number of commonly seen non-compliance content as negative examples for reference. Though it may still depend on SAPPRFT's discretion when it comes to grey area issues, no doubt the Content Standard can be used as a practical and useful guideline for mobile game developers, publishers and operators targeting China market to understand what kind of game or game content is explicitly forbidden to China-based fans. It is advisable to bear in mind the Content Standard in the whole process of game planning, development, production and localization and to conduct a thorough compliance check according to Content Standard before the submission of application to SAPPRFT so that to ensure the game will be approved as planned.

No Other Language Policy

There have been discussions on whether English is completely prohibited in game content. According to SAPPRFT, as a general principle, simplified Chinese should be the only language used in any game. However, for certain English wordings (such as brand names or trademarks), if no appropriate Chinese translations are readily available, then English wordings may be exceptionally allowed.

Game Name

SAPPRFT also follows quite strict rules on the game name. Needless to say, the game's official name must be in simplified Chinese. Game name also needs to be closely relevant to game content or gameplay. More importantly, it cannot be identical to or confusingly similar to that of other online game (including mobile, web, client game and etc.) which has been approved by SAPPRFT, or is currently under SAPPRFT's review or is famous in the market unless otherwise authorized by relevant copyright holders. SAPPRFT's such rigid requirement on game name would be very helpful to eliminate passing-off, but it also raises the bar on the relevance and uniqueness of naming a game. Foreign developers are advised to work closely with its Chinese partners on picking proper and compliant game names in Chinese. In particular, as bad-faith trademark registrations remain commonplace in China, it is highly recommended to file the trademark application of such names as soon as they are determined and prior to the submission of applications to SAPPRFT if possible.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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