"Circumstance" was financed primarily in the U.S. and competed in the U.S. section of the 2011 Sundance Film Festival (where it won the Audience Award). However, it was also shot in the Farsi language and, according to PGA rules, only English-language films qualify for awards consideration.
In their response, the PGA says that they plan to revisit the rules, but note that "we are too advanced into our awards process this year to make changes for our 2012 honors."
Producers Guild of America response to Karin Chien's open letter:
We appreciate the passion and commitment behind responses such as Karin Chien’s, who has every reason to be proud of her work and the acclaim her film is receiving.
Unfortunately, the Producers Guild has not recognized foreign language films as eligible for its awards because of the unique position the Guild holds with regard to producing credits and producer award eligibility. Unlike other Guilds’ honors, the Producers Guild Awards require an exhaustive analysis of the circumstances of the production and the various creative and logistical contributions of the films’ credited producers. Furthermore, such analysis must be performed in a compressed timeframe during the height of awards season.
Our awards eligibility process is a thorough one, requiring all eligible producers to have undertaken a majority of the producing functions on a given film. This determination cannot simply be handled via statements by the producers in question, but necessitates the confidential receipt of verified affidavits from department heads and other significant creative contributors to the film.
When we have attempted this process with foreign-language films in the past, we found that participants were unable to respond in a timely manner, in part because of the distances involved, and as significantly, because of language barriers. (Our Guild does not maintain a translation service, nor do we possess the funds to engage one.) The Producers Guild has staked its reputation on the integrity of its process for determining which credited producers performed a majority of the work on their films. If the Guild cannot make that determination with confidence and confidentiality, it cannot rightly honor a film or its producers.
In short, circumstances have conspired to make the present difficulties surrounding the determination of award eligibility for foreign language films more than problematic. That said, we will be revisiting this rule with the help of our Awards chairs, our International Committee and our Independent Film Producers Committee. We are too advanced into our awards process this year to make changes for our 2012 honors. However, if after our reassessment and analysis, we can find a way to adjust our process so as to make feasible the extensive and confidential research required, we will certainly consider non-English language films for our awards in the future.