Should difficulty be considered in rating a game (ESRB)

[MrT-Tar]

difficulty can be very very subjective.  For example, I rarely find even 'tough' puzzles hard (Some in games like Alundra did challenge me though), however I find some action heavy parts harder and often even average QTEs and the like.  I'm sure its visa versa for someone else.

There is also the argument that the PEGI/ERSB rating couldn't take into account experience or a lack of, a major contributor to difficulty.