SUBTITLES

TV spots

Or how to ensure universal access to TV commercial films by reaching 5.4 million deaf or hard-of-hearing people in France.

Thanks to the law of 11/02/2005, since February 2010, 100% of programs on channels with an average annual audience exceeding 2.5%* of the total audience are accessible to deaf and hard-of-hearing individuals… with the exception of advertising messages.

Being proactive with your clients regarding the subtitling of commercial films is meeting their expectations for more responsible communication.

* 40% of programs for channels with an audience < 2.5%
20% of programs for channels not using frequencies assigned by CSA.

WHAT ARE WE TALKING ABOUT?

We are talking about subtitling that:

• Does not directly replicate the original version/dialogues, as they are often simplified due to limited character availability.

• Indicates sounds, music, etc., that impact the story.

• Only appears when individuals activate the subtitles/Teletext option using their remote control.

HERE’S THE EXPERIENCE A DEAF OR HARD-OF-HEARING PERSON HAS WHEN EXPOSED TO AN UNSUBTITLED ADVERTISEMENT:

HERE’S THE SAME TV SPOT IN ITS SUBTITLED VERSION:

HOW DOES SUBTITLING OF A COMMERCIAL FILM WORK?

Subtitling for the deaf and hard-of-hearing differs from “traditional” translation subtitling, as deaf and hard-of-hearing individuals cannot rely on the program’s audio environment for scene comprehension (often rich and sometimes crucial). This requires:

Increased time for visual discovery.
Subtitles adapted in terms of length (maximum of 12 characters per second), necessitating a true intralinguistic translation (not everything that is said is written).
Precise description of the program’s sound universe (sound effects, musical tone, etc.).

This subtitled content, hidden within the digital signal, is activated by the viewer using their remote control.

HOW TO SUBTITLE A COMMERCIAL FILM?

Subtitle production time

Subtitling can be seamlessly integrated into the timeline of a digital delivery. In fact, within a few hours (up to a maximum of 4 hours), the subtitling process is completed and ready to be delivered to the channels after approval from the client. It runs parallel to the request for pre-broadcast clearance, ensuring no delays in delivery.

Spotting & Simulation

A specialized subtitler detects the audio and transcribes it into encoded subtitles. These subtitles are precisely positioned according to specific guidelines to ensure readability and comprehension. Given the visual content of a commercial film, this positioning is delicate and requires specialized teams. These operations are carried out using specialized software and tools.

Validation

The subtitles are overlaid onto the film to simulate the final appearance. This simulation is provided to the client as a file for verification and editorial approval.

STL file or Ceefax insert

Depending on the channels, subtitles take the form of a dedicated file known as an “STL” file that accompanies the broadcast video file or they are inserted as encoded data in the invisible lines of the video signal.

Delivery

The broadcast video files and subtitles are delivered according to the defined workflow with each broadcaster or channel.

GO FURTHER

ARCOM SUBTITLING QUALITY CHARTER

Regarding subtitling, the mission of ARCOM is derived from Law No. 2005-102 of February 11, 2005, on equal rights and opportunities, participation, and citizenship for persons with disabilities, which introduced several paragraphs to Law No. 86-1067 of September 30, 1986, on freedom of communication.

Furthermore, Article 20-6 of the Law of September 30, 1986, created in December 2020 as part of the transposition of the new European SMA directive, states that in addition to the volume of accessible programs, ARCOM ensures the quality of this accessibility.

ARPP GOOD PRACTICE GUIDE FOR SUBTITLING ADVERTISEMENTS.