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PEGI gives Balatro an 18+ rating for gambling imagery
(files.catbox.moe)
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But poker is only a gambling game because when you play it you "give up" something of value in the hope of winning more through playing and randomness. What makes it gambling is not the cards or the chips it's the gambling aspect. Balatro uses card and poker hands, and so does "yatzhee", but it does not use any gambling mechanic. Lootboxes on the other hand use gambling mechanic.
Which is why PEGI didn't say it was literally gambling, they said it was imagery of gambling.
Although you may be right about why they did it, I feel like imagery of gambling is not meant to be 'something that is in any way related to something that happens to be gambling', it's when gambling is shown but you're not the one gambling. If someone in game is gambling that's imagery, if a game uses cards for something that is not gambling it's not imagery.