Open letter from UNTERTITELFORUM & ATVE to the European Commission

Open letter on the EU Commission’s “initiative to crowdsource subtitling to increase the circulation of European works”

As professional subtitlers, we would like to voice our concerns about this initiative. In your summary, you mention the high costs involved in subtitling of between 600 and 1,000 euros per film. This is a rough and fairly low estimate. Even with the kind of time-saving professional software most subtitlers use, subtitling a feature film can take anything from four to ten days, depending on the length of the film and the complexity of the dialogue. As it is, professional subtitlers often earn hourly rates that are below the minimum wage, even though most are university-educated, experienced language practitioners. Financial pressure has been mounting for years. As a result, the rates for subtitling have dropped to a level that has often become unsustainable, forcing many to leave the profession altogether. In view of this, you may imagine our consternation when reading about your well-meaning initiative. Your aim is to increase the supply and the visibility of European audiovisual works online and increase their proportion in catalogues of VOD services available in the EU”. To make this possible, you would like to find ways to subtitle the films completely free of charge. We would like you to consider the following questions:

  1. Do you really want to outsource the business of subtitling to amateurs or machines? Condensing the film dialogue to make it readable while retaining all of the essential information, the language register and allusions to previous dialogue or future sequences within the film is not an easy task. Subtitlers need to have a feeling for the audio-visual medium as well as for the languages involved. They must have training, experience, technical understanding and the will to rewrite a subtitle as often as is necessary to convey the message and ensure that it can be easily read in the time available. As far as machines are concerned, they are still barely able to translate standardised texts let alone spoken language, which lives from colloquialisms, word play and many other features that a machine cannot grasp.
  2. How do you plan to prevent copyright infringement if one or possibly even several amateur translators are subtitling a film?
  3. What kind of workflow do you envisage? Do you plan to contract expensive editors to revise translations that have been produced quickly and by amateurs? Any professional translator will tell you that it takes longer to correct a bad translation than to translate the text from scratch.
  4. Are you suggesting that professional filmmakers and screenwriters place the fruit of years of hard work into the hands of people who could, potentially, ruin the reputation of their film overnight for the sake of a few hundred euros? Contrary to general public perception, subtitling is NOT just a translation of the text. Bad subtitling can make a mockery of a film or even render it unintelligible if dialogue is poorly translated or the translations too long for the time available, meaning that the audience are not able to follow the plot. Subtitles created through crowdsourcing projects are teeming with these kinds of errors.

If the EU is serious about wanting to provide a larger range of smaller films to a wider audience, then trying to find ever-cheaper solutions for subtitling is not the solution. No filmmaker would dream of appointing their neighbour as DOP just because they had purchased a video camera. Instead, the EU commission should try and make subtitling a standard part of the post-production process and ensure that the professionals involved receive fair rates of pay. As long as the translation of film dialogue is perceived as an inconvenient afterthought that is not accounted for in the film’s budget, subtitling will never receive the recognition it deserves. Crowdsourcing subtitling can only damage a film’s international reputation. Everyone is a loser in this scenario: decent subtitles do not come for free!

The members of Untertitelforum
The members of AVTE, AudioVisual Translators Europe
Hinrich Schmidt-Henkel, President of VdÜ (German Association of Literary Translators)
Eva Leipprand, President of VS (German Writers Association)

Berlin, September 2015

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