Does Measures for the Labeling of AI-Generated and Synthetic Content require Conformity Assessment?
China • enforcing
Yes — 1 provision
Requirements at a glance
This regulation imposes 5 specific requirements for Conformity Assessment across 1 provision:
- Verify metadata — Dissemination platforms must check whether file metadata contains an implicit label; where the metadata clearly marks content as generated, add a conspicuous prompt around the published content stating plainly that it is generated content (Article 6(1))
- Handle user declarations — Where no implicit label is found but the user has declared the content as generated, add a conspicuous prompt stating the content **may be** generated (Article 6(2))
- Detect suspected content — Where there is neither an implicit label nor a user declaration, but the platform detects an explicit label or other traces of generation, classify it as **suspected** generated content and add a conspicuous prompt saying so (Article 6(3))
- Provide labeling function — Provide the necessary labeling function and prompt users to proactively declare whether published content contains generated content (Article 6(4))
- App store listing check — At listing or launch review, app distribution platforms must require the app provider to state whether it offers AI generation or synthesis services, and where it does, must verify the provider's content-labeling materials (Article 7)
Platform Label Verification
The compliance dimension the Deep Synthesis Provisions do not have: duties that bind actors who never generated the content. Article 6 makes every covered network-information-content dissemination-service provider a verifier with a three-tier response, and Article 7 adds an app-store listing check.
Requirements
| Requirement | Details |
|---|---|
| Verify metadata | Dissemination platforms must check whether file metadata contains an implicit label; where the metadata clearly marks content as generated, add a conspicuous prompt around the published content stating plainly that it is generated content (Article 6(1)) |
| Handle user declarations | Where no implicit label is found but the user has declared the content as generated, add a conspicuous prompt stating the content **may be** generated (Article 6(2)) |
| Detect suspected content | Where there is neither an implicit label nor a user declaration, but the platform detects an explicit label or other traces of generation, classify it as **suspected** generated content and add a conspicuous prompt saying so (Article 6(3)) |
| Provide labeling function | Provide the necessary labeling function and prompt users to proactively declare whether published content contains generated content (Article 6(4)) |
| App store listing check | At listing or launch review, app distribution platforms must require the app provider to state whether it offers AI generation or synthesis services, and where it does, must verify the provider's content-labeling materials (Article 7) |
Penalties
| Violation | Fine |
|---|---|
| Any violation of the Measures |