Content Restrictions and Requirements For Publishing Games In China (2020)

Background

Beginning July 2016, all games published in China (mobile or otherwise) must go through a licensing and approval process with the National Press and Publication Administration (NPPA) – formerly the State Administration of Press, Publication, Radio, Film and Television (SAPPRFT).

Note: In older documents, SAPPRFT was called the General Administration of Press and Publication (GAPP), as this agency was later merged with the State Administration of Radio, Film and Television to form the SAPPRFT. It is was also sometimes referred to as the General Administration of Press, Publication, Radio, Film and Television (GAPPRFT). Later, the agency was split into the National Press and Publication Administration (NPPA) and the National Radio and Television Administration (NRTA). The NPPA now handles game licenses.

Another agency to note is the Cyberspace Administration of China (CAC), formed in 2014. The CAC is the primary regulator, censor and policymaker for China’s internet industry, and primarily oversees websites, e-commerce, search engines, and apps.

At that time, the agency released a detailed list of content restrictions that remains in effect to this day, but with some additions. Game published before that time were required to resubmit and go through the approval process.

In 2007 and 2011, SAPPRFT issued notices stating that real name verification of online gaming accounts must be implemented for all online games as part of its anti-gaming addiction program.

Later, in November 2019, SAPPRFT (now called the NPPA) released a notice requiring online games to restrict access to games during weekdays evenings and add in-app purchase spending limits for children under 18, once again noting that the real age account verification system must be implemented in order to enforce it.

Requirements

Game Startup Procedure

• Before the game starts, a screen with the required “Healthy Gaming Advice” text must be displayed:

健康游戏忠告
抵制不良游戏，拒绝盗版游戏。
注意自我保护，谨防受骗上当。
适度游戏益脑，沉迷游戏伤身。
合理安排时间，享受健康生活。

• After this, a special page must display the game copyright owner, publisher, NPPA game license number (ISBN / GRN), and other approval document numbers as appropriate. 
  
• Like all mobile apps, your game must include a privacy policy and terms of service that users must agree to. China’s Ministry of Industry and Information Technology (MIIT) is very stringent as to the content and scope of these policies and exactly how this policy is displayed to the user.

Link: Privacy Policy Requirements For Mobile Apps In China

Game Content Restrictions

In addition to the types of games that are not allowed, here is a broad overview of the in-game content that will cause your mobile game license application to be rejected in China.

These restrictions are all-encompassing, referring to the language, script, story, maps and scenes, character designs and models, in-game items, music and sound effects, missions and quests, instructions, and advertisements in your mobile game.

Your mobile game cannot include any content that:

• “Opposes the basic principles established by the Constitution” and is interpreted as slandering or demeaning the military, government, socialist principals, Mao Zedong Thought, or the leadership.
• “Endangers national unity, sovereignty and territorial integrity” by misrepresenting Taiwan, Hong Kong, the South China Sea, and China’s established borders and political entities in real or even fictitious maps.
• Distorts historical facts about modern, historical or Imperial China, or paints its various ethnic groups in a bad light.
• Depicts real or fictitious foreign entities invading Chinese territory, embassies, waters, etc.
• Discloses state secrets and confidential information.
• Promotes fascism, glorifies war, violence, or criminal activities.
• Depicts religious activities or the supernatural, such as cults, fortune-telling, ghosts, zombies, vampires, etc., or using the banner of science to fabricate or reproduce the supernatural in real life.
• Depicts obscenity or pornography, nudity, homosexuality, polygamy, adultery, or sex in any form, including sexual taboos.
• Content that promotes violence, terror and cruelty, such as torture, corpses, skeletons, blood of any color, mass destruction.
• Scenes, characters or images that are too scary.
• Content that “insults or slanders others, or infringes upon the legal rights and interests of others” and invades their private lives.
• Content that “endangers social morality or national excellent cultural traditions” such as vulgar words, destruction of cultural buildings or relics, insulting socially disadvantaged groups, promoting corrupt lifestyles and the use of power or money for personal gain, or painting historical China and Chinese culture in a bad light.
• Promoting violations of laws and crimes, particularly involving minors and criminal organizations, or playing the role of a thief or criminal.
• Promoting drug use or drug trafficking.
• Gambling or gambling equipment, providing services for game point transactions, exchange, or disguising exchange of cash and property in the form of “virtual currency”.
• Encouraging minors to use tobacco or alcohol, get married, live together, or do other actions unsuitable for minors.

For a more detailed explanation and thorough list of the 2016 guidelines, see our translation of the official 2016 Mobile Game Content Standards.

Link: Detailed List Of Restrictions

In 2019, a few additional clarifications were given along with the new submission process:

• No more mahjong or poker games. At least for the time being. Thousands have already flooded the market and are widely seen as encouraging gambling.
• No corpses, skeletons, zombies, vampires, pools of blood, or blood of any kind in any color. When a character or player is killed, they should simply disappear. Changing the color of blood will no longer be enough.
• No collecting of concubines and wives, no matter how historically accurate they may be in your feudal China game.
• Cultural considerations. In an expressed desire to increase the quality of games on the market, the government encourages developer to keep China’s core social values in mind and promote China’s traditional history and culture. Games must contain “correct” information regarding politics, law, and history, as interpreted by the authorizing agency.
• Security Assessment Form. You probably already know that the Chinese government restricts any speech that has potential to “disrupt the public order”. Although games are not typically forums for political activism, any social aspect to your game where players can communicate with each other is required to have process in place for reporting and handling these violations. You will need a Security Assessment Form on file with the appropriate government agency that details your system and process.

Loot Box Restrictions

Chinese law is particularly strict and detailed on loot boxes, as they are seen as a form of gambling:

• Loot boxes cannot be purchased using either real or virtual currency.
• Loot box contents must also be acquirable through other means.
• Compulsion loops are not allowed.
• Developers have to disclose the odds for individual items in loot boxes, and those odds must reflect reality over time. So, for example, anything with a 10% chance of appearing must actually do so once the player has opened 10 loot boxes. This also means that a player would be guaranteed to receive even a rare item after they open a certain number of loot boxes.
• A publicly available record of loot box outcomes for the last 90 days.
• Clear in-game display of a player’s daily limit showing how many loot box opens they have left.

Publishers must also limit the quantity of loot boxes a player can open in a day, and give a clear in-game display showing the player how many opens they have left:

• No more than 30 single loot boxes in a day.
• No more than 3 “10x” loot box bundles in a day.
• No more than 50 boxes total in a day.

China’s loot box laws are difficult to police, and they tend to be enforced unevenly. For example, for Overwatch in China, Blizzard decided to allow purchase of in-game currency with real money, and threw in loot boxes as a “free bonus” for the purchase. Because of the complexity of these rules, many publishers choose to remove loot boxes entirely from the Chinese version of their games.

Link: Loot Box Design 2.0 (outside link)

Social and Communication Elements

To the extent that your game allows players to talk with each other or post messages within the game or online, your game will need an established method to control, monitor, and moderate this content. You will need to submit your plan for dealing with reported issues and content takedowns, and you will also need to install filtering software to automatically block harmful and illegal content.

We expect to see more detailed restrictions on socialization in online multiplayer games in the wake of April 2020’s unofficial Animal Crossing: New Horizons ban. The popular Nintendo Switch game was pulled from e-commerce retailers in Mainland China in April 2020 after authorities realized some players were using in-game elements and map-modification features to stage virtual protests in support of Hong Kong’s pro-democracy movement. Some have speculated that the new laws may also prohibit gamers from meeting and chatting with gamers outside the Great Firewall.

Plagues, Map Editing, and Organizing a Union

Due to the Animal Crossing incident and the politically-sensitive nature of the COVID-19 pandemic (which also led to the removal of the popular mobile game Pandemic, Inc. from China’s app stores), authorities are also expected to issue new laws banning plagues, map editing, and “organizing a union” inside games. These are undesirable because map editing could be used to promote a geographical split of the motherland, while references to viruses, plagues and pandemics could be used to covertly refer to the COVID-19 virus in a way that is slanderous to China and Chinese people. Details on these items have yet to be announced or finalized.

Link: 4/10/2020 Game Grapevine Forum on Potential New Game Regulations in China

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