【交通消息】多人撞車！
明明只係個導演唔識程序咋喎，
吹到咁大俾人 censor？
上好個字幕檢多次咪得囉。
An open letter to the public & media:
Regarding: Hong Kong Censorship Certificate issued to the feature film CHRISTMAS AT THE ROYAL HOTEL
On May 4th, 2018, I submitted the film to Hong Kong’s Office for Film, Newspaper and Article Administration for receiving a film rating / classification from the film censorship board. Later that month, I then picked up my censorship certificate card at their office upon payment of $7,085 HKD. The film received a rating classification of IIA (roughly equivalent to a PG rating in the USA).
In early July, I scheduled three public screening dates at the Hong Kong Film Archive cinema for August 27, September 12 and September 26. As required, I submitted the film’s promotional materials (poster & leaflet designs) for vetting. In the promotional materials I included the fact that these upcoming public screenings of the English language film would include Chinese subtitles. A few days later I received an email from the Censorship Authority that my current Hong Kong film censorship card would no longer be valid if I used Chinese subtitles on the film.
The Hong Kong Censorship Authority’s position is that if I were to add Chinese subtitles to CHRISTMAS AT THE ROYAL HOTEL, then that would be considered a “modification” of the film and thus my censorship certificate would not be valid for publicly screening the film with Chinese subtitles.
From a filmmaker’s perspective, a modification of a film would be to reedit the film by adding or deleting picture or soundtrack elements. The idea that a film is “modified” by the addition of subtitles is an expansive interpretation of Hong Kong’s vague censorship regulations.
Hong Kong censorship ordinance never mentions the word “subtitles” in the regulations, but is does state the following:
(c) endorsed with a condition that the film shall not be exhibited with—
(i) any additions to; or
(ii) any excisions from,
the film in the form in which it was submitted under section 8;
Hong Kong’s Censorship Authority has decided its mandate does allow it to regulate the use of subtitles on films. My film’s current Hong Kong censorship certificate (#FMC025892) does not allow any subtitles for public screenings. Thus the upcoming film screenings of CHRISTMAS AT THE ROYAL HOTEL in August and September will only be in English, which is a major stumbling block for accessing the Chinese language community.
I have been informed by the Censorship Authority, “If you are going to screen the captioned film with Chinese subtitles, you have to submit that version for censorship and obtain another film certificate for public exhibition.” So while Hong Kong’s censorship ordinance is rather vague that subtitles actually need approval by the censorship authority, they are now making it crystal clear that they feel the need to regulate subtitles seen by Hong Kong audiences.
Regulating the use of subtitles has the perverse effect of being discriminatory to minority language groups and hearing impaired people in Hong Kong. On a technical level it is easy to provide a subtitled film in Hindi, Filipino or French, but when you require every language group to apply for a censorship certificate with its expensive fees, then these minority groups will be adversely affected. That is not a good policy for Asia’s World City. The use of subtitles in a film is to allow an audience to understand the film in their native language. Subtitles also help those members of our community who are hearing impaired.
Before I applied to the censorship authority, I did read all the regulations and guidelines. It should be the responsibility of government to write clear regulations, not to have a system where only inside film industry people can understand. When the government imposes censorship regulations on the public, it should do so with full transparency. Otherwise it leaves everyone guessing why the vague rules are being applied in a seemingly unpredictable way.
I would encourage interested citizens to read Hong Kong’s censorship ordinance to come to their own conclusions on the application of these censorship regulations.
All the best,
Craig McCourry
Director ~ CHRISTMAS AT THE ROYAL HOTEL
August 11, 2018
UPDATE: August 13, 2018
The recent media coverage on the Chinese subtitling issue on CHRISTMAS AT THE ROYAL HOTEL hopefully may serve as a “teaching moment” for the Hong Kong Censorship Authority and filmmakers. It would be helpful if the censorship authority would update their guidelines on their website and publications regarding their interpretation that subtitles cannot be used unless submitted at the time of the censorship examination (hint: using the word “subtitle” would be helpful in their guidelines). If they decide not to provide clarity on the use of subtitles, then at least the recent media coverage has provided filmmakers a bit of a warning on this subtitling issue in regards to Hong Kong’s Censorship Ordinance regulations.
These three upcoming film screenings at the Hong Kong Film Archive will probably be the only cinema screenings in Hong Kong. If I can find one cinema in Hong Kong willing to screen the film for a short run, I will then resubmit the film again to the Hong Kong Censorship Authority that would include Chinese & English subtitles. But finding one cinema in Hong Kong to do this will be a long shot.
