Phenomenon Studio | Interview with Guo Zhenming, the person involved in the “Unauthorized Film Production Case”

At the end of March 2025, news spread online that image creator Guo Zhenming was fined 75,000 yuan and his equipment confiscated by the Urumqi Municipal Bureau of Culture and Tourism for filming videos. Phenomenon.com interviewed the person involved.

Phenomenon.com: What exactly happened?

Guo Zhenming: It’s like this. Last September, I traveled to Xinjiang and talked to a musician from the mainland, Wang Xiao, about recording his creations and field trips. He does contemporary music, like improvised instruments and vocals on the spot. We came up with the idea of traveling, creating along the way, and conducting folk field trips, filming as we went. Xinjiang is a place with a particularly ancient and rich cultural and musical heritage, and the magnificent natural scenery also captivated us. We traveled between the cities and villages of North and South Xinjiang, Urumqi, and lingered. In addition to the creation in the improvised environment, we also collected many unique instrument performances by folk musicians. For these performances, some folk artists asked for some fees, but many were friends, and they were free. The whole process was completed from about December last year to January this year, just the two of us, I filmed his creation and field trips. Later, the people from the Urumqi Municipal Bureau of Culture and Tourism came to the door to inspect and said that according to the report, I was “suspected of unauthorized film production” and sealed up my equipment and materials.

Phenomenon.com: What is the basis for their administrative inspection and punishment?

Guo Zhenming: The law enforcement officers of the Culture and Tourism Bureau couldn’t explain which article of the “Film Industry Promotion Law” they were based on at the time. They just said, “Go to Baidu to check.” They are not familiar with these articles either. I later asked a lawyer and checked it myself. I think that most film and television art workers and ordinary people may not know the “Film Industry Promotion Law”, Article 13 stipulates that “legal persons and other organizations that intend to produce films shall submit a synopsis of the script to the film authorities for record.” I think everyone should pay attention to this legal article and study it.

Phenomenon.com: Do you think your filming behavior violates Article 13 of the “Film Industry Promotion Law”, which states that “films to be produced must be filed with a script outline”?

Guo Zhenming: I don’t think it constitutes a violation of Article 13 of the “Film Industry Promotion Law” at all. There are several issues involved here:

Whether it is ordinary people or artists, using professional or non-professional equipment to shoot videos is a freedom of cultural and artistic creation of an ordinary citizen, because this is a personal behavior.

Article 13 of the “Film Industry Promotion Law” requires filing by legal persons and organizations, that is, industrialized, corporatized, and departmentalized film production; film production is an extremely complex industrial behavior and departmental activity composed of various film creators and film technicians, and requires large-scale financial support. Its creators and technical personnel include at least producers, directors, screenwriters, actors, sound engineers, lighting engineers, photographers, makeup artists, on-site editors, producers, field recorders, assistants, etc., a basic crew composition. Can an ordinary person with a camera make a movie? I am talking about the kind of film production that the “Film Industry Promotion Law” wants to regulate.

Even if my recording and filming behavior is defined as a film, where does my documentary work come from a script outline? This shows that the people who formulated the “Film Industry Promotion Law” did not pay attention to the essential difference between documentaries and films. Documentaries do not have scripts, only films have scripts. How can documentaries have “film script filing”? Even if documentaries are defined as films, they are films without scripts. How can the “Film Industry Promotion Law” require them to “file a script” for film works without scripts?

Film festivals are not equal to cinemas. The image works exhibited at international film festivals are different from the films shown in cinemas, which are very broad. Videos taken by mobile phones are also films, and short videos are also films. The people from the Culture and Tourism Bureau believe that I participated in international film festivals with documentaries last year, and thus determined that the video materials I filmed had film attributes, violating the “Film Industry Promotion Law”. Do you think this determination is in line with legal logic?

Phenomenon.com: What do you think the outcome of this case will be?

Guo Zhenming: My case is the first case in China of “unauthorized film production” (Note from Phenomenon.com: Regarding this statement by the person involved, Phenomenon.com does not necessarily agree with the historical facts, and the interviewee’s statement is for reference only). The discussion space in jurisprudence is very large, and this case will definitely have a great impact. I will continue to go through the procedures of hearings, administrative reconsideration, and administrative litigation. Of course, I am an ordinary art worker, and you know that people like us are very difficult. I can’t afford the fine, and the lawyer and litigation fees are also a great pressure on me.

If my filming behavior violates the “Film Industry Promotion Law”, then so many students and graduates of film and television, drama, media, and fine arts majors in China will consider whether their graduation creations are illegal? Have they filed their documentaries, films, and image works?

I hope to get the attention of society, because every ordinary citizen, when picking up a camera or mobile phone to record and create in the future, should consider whether they have violated the “Film Industry Promotion Law”? Are you “unauthorized”?

The following is the “Notice of Prior Administrative Penalty” issued by the person involved.