About a year ago, I found myself learning more about film ratings than I ever cared to. At the time, I posted a Bluesky thread but I still think it’s a pretty fascinating bit of trivia so this is my attempt at a slightly more long-form version.

Before we begin, you might wonder why film ratings of all things and I remember it quite clearly.

At that time, I had been lying to myself that I would get back into running¹ so I put all of my gear on and then… I started procrastinating. FYI’s OIA categorisation game was my particular addiction at the time as I had set a Beeminder goal to categorise about 10 OIAs per day.²

On that particular day, the categorisation slot machine gave me this OIA asking for ratings information on Final Fantasy XVI, which I had been playing around that time as well. I gave the response a skim, not really knowing what I was looking at, and on Page 21 I spotted the words “Film & Video Labelling Body”.

That name (or entity) wasn’t familiar to me but it seemed a little off that it sounded official. I had a look at the address on Google Maps and… it’s some sort of industrial warehouse? What’s going on there?

Before we solve that mystery, let’s explain what the Film & Video Labelling Body actually is.

Who rates your films?

Whenever you see a piece of media, whether it’s a game, a movie or even on a streaming service, it almost always carries a rating.

That rating almost usually looks like one of these stickers which older readers will recognise from physical media like DVDs, game boxes and so on but with streaming, they’re less and less common. You may even spot them on movie posters, although I can’t say I’ve personally looked too hard.

The Film & Video Labelling Body, or FVLB for short, is the Labelling Body for New Zealand that actually issues these labels.

Isn’t that what the Office of Film and Literature Classification (OFLC) for, you might be thinking? I had assumed that too but the process is a lot more kafkaesque than you might imagine.

When it comes to films specifically, they are all submitted to the FVLB first who follow the process outlined on page 2 of this document

If the film is unrestricted (meaning G/PG or M material), or it has already been rated before, then the FVLB provides a label for a small fee without further viewing.

If the film has not been rated in either New Zealand, Australia or Britain but does not have restricted content, the Labelling Body Community Representatives (who work for the FVLB) view the film directly for a fee.

If, however, the film has not been rated in New Zealand and contains restricted content, it will be passed on to the OFLC to be rated.

When it comes to videogame, they are actually entirely exempt from requiring labels unless they contain restricted content. They’re still submitted to the FVLB but are then forwarded straight on to the OFLC.

Things get a bit more confusing when you realise that the Film and Video Labelling Body happens to be the current labelling body but technically could be replaced by some other entity entirely, if the Minister for Internal Affairs decided for whatever reason.

The FVLB is an incorporated society and they’ve been strugging since 2016 for a couple of reasons.³

The Decline of Ratings

There are two main issues that have impacted the FVLB over the years:

1. Declining sales of physical media
2. Commercial Video on Demand Providers (CVoD) or streaming platforms in other words.

Physical media is fairly straight forward. When labels are applied for, a fee is paid to the FVLB. The less DVDs and blurays there are to rate, the less fees there are due to the FVLB.

The second, and probably worse issue, are the various streaming platforms (Netflix/Disney+/Amazon Prime Video etc).

In order to speed up their ability to import content, and to avoid flooding the FVLB/OFLC, most streaming providers are allowed to perform their own self-rating of content, which also means that the FVLB does not receive any fees. They do have to pay an annual levy to the OFLC however.

With both of these things combined, not to mention the supposed never-ending death of cinemas, you do have to wonder where the FVLB is going to get its funding from.

Running out of money

As part of this rabbit hole, I asked the Department of Internal Affairs for documents about the financial health of the FVLB so we can actually tell the rest of the story in their words.

In October 2020, the FVLB advised, based on current and predicted costs, fee income and reserves would be sufficient to cover their operating costs for 2021, and potentially some of 2022. However, the FVLB’s financial situation has continued to deteriorate, and it has approached the Department for additional financial support.

The dramatic decline in physical media means the FVLB cannot generate enough fee income to cover its costs. Revenue from theatrical releases (which have been severely impacted by COVID-19) cannot cover the shortfall. The situation has been exacerbated by The Warehouse’s recent decision to stop selling DVDs and Blu-ray discs.

I can’t say I had realised that The Warehouse stopped selling DVDs or Blu-rays but it’s fascinating to think that doing so was slightly load-bearing for the FVLB’s survival.

While the Budget for 2020 declined to fund the FVLB, it was extended a grant to keep it afloat until a 2022 Budget bid could be entered.

Further down in that stack of documents, we can see a “Budget 2022 Initiative Summary”. On Section 2: Cost pressure information, we get a fascinating glimpse at just how close New Zealand’s ratings system may have come to collapse.

Under “Cost pressure description”, we see:

The cost pressure is critical: the FVLB and its functions are critical to the operation of New Zealand’s classification system. Its reserves are nearly exhausted, and if the Body becomes insolvent, there will be no mechanism to rate or label films, nor to submit films to the Office of Film and Literature Classification (the Classification Office) for classification.

and under “Case for funding”, we see:

Without the FVLB, the New Zealand classification system will be unable to function. Film importers and distributors will be unable to obtain the ratings, classifications and labels required to sell and screen movies legally. This will affect their revenue streams and have flow-on implications for cinemas and sellers of films and DVDs.

What’s the fix?

A July 2021 memo titled “Film and Video Labelling Body funding” outlined what the Department of Internal Affairs seemed to view as the only real option:

The transfer of the FVLB’s functions to the OFLC would appear to be the only viable long-term solution to maintain the integrity of the classification system, including protecting minors from harmful content and providing guidance to parents

To my knowledge, this never passed the memo stage and the FVLB continued on as normal, being kept afloat with 3 installments of $150,000/year from the 2022 budget bid.

As part of that arrangement, the FVLB was required to provide a financial report to the Department of Internal Affairs every 3 months up until the funding expired on June 30th, 2025.

In a March 2025 cabinet paper, it was suggested that perhaps the CVoD/streaming style approach of self-labelling should just be extended across the board to include movies, DVDs and games.

I intend to review the arrangements for commercial content labelling under the Films, Videos, and Publications Classification Act 1993 (the Classification Act) as part of my 2025 work programme, which would consider extending the CVoD regulation approach to films for cinematic release, DVDs, and games. The levy would be reviewed as part of this work programme.

This would mean the death of the FVLB as we know but it seems that none of this has progressed in any meaningful capacity.

According to the latest annual return for the FVLB, it seems they’re still just barely trucking along, apparently with a new tranche of $150,000 grants from the government.

I suppose I’ll need to file another OIA to find out the latest installments in this very niche story.