The draft German Film Law has drawn further criticism from four film industry trade associations and a group of independent producers.

The home entertainment trade body, the exhibitors association, the multiplexes' association and the arthouse cinemas' guild described the bill as "inconsistent, half-baked and not acting in solidarity".

And while they stressed that this did not constitute a total rejection of the proposed new Film Law, they said " the submitted draft is quite plainly unacceptable."

Exhibitors and video companies reject the proposed 1% increase in the levies on their annual turnovers. In practice, this would mean an increase of between 40% and 67% in levy payments for the cinema-owners, for example.

Meanwhile, culture minister Christina Weiss' proposal to consider international festival invitations and prizes in the calculations for the retroactive "reference" funding has failed to mollify a group of independent producers including Egoli Tossell, Pandora Filmproduktion and zero film.

Taking Iain Dilthey's The Longing (Das Verlangen) as a hypothetical example, one can see the problems likely to be encountered under the proposed new regulations. Das Verlangen was invited to compete at last year's Locarno Film Festival where it won the Golden Leopard. According to the new rules it would receive a total of 200,000 reference points. However, if this film did not reach the minimum threshold 50,000 admissions in Germany - a tall order given the current state of German distribution - these festival points would be worth nothing.

According to a growing number of producers, the international sales performance of German films should also contribute to a film's "reference" points total.

However, Minister Weiss explained that the consultative phase on the Film Law, which comes to an end on April 23, would give her a chance "to reflect and we can also correct certain elements if they ought to be corrected."