TYGlobe

Content Interpretation

The *Measures for the Labeling of Artificial Intelligence Generated and Synthesized Content* (hereinafter referred to as the "Labeling Measures"), jointly issued by four competent authorities, is of far-reaching regulatory significance and ecological restructuring value for the film and television industry. Through the dual regulatory norms of "explicit labeling" and "implicit labeling", the Measures draw boundaries for the lawful application of AI technology in film and television creation, and provide institutional guarantees for the sound development of the industry.

First of all, the explicit marking requirement has enhanced the transparency and credibility of film and television works. According to relevant provisions, AI-generated videos shall be affixed with prominent marks such as texts, icons or voice prompts at the opening frame, around the playback area or at the end. This measure can effectively remind viewers to distinguish between real-shot content and AI-synthesized scenes, especially in fields including special effects production and virtual character generation, so as to avoid misunderstandings caused by viewers' confusion over relevant technologies. For example, if AI face-swapping technology is not clearly marked, it may trigger false publicity or copyright disputes, while mandatory marking reduces such risks from the source.

Secondly, the metadata tracking mechanism with implicit identifiers has strengthened copyright protection and liability tracing. Content attribute data such as producer information and service codes shall be embedded in AI-generated files of film and television works. This not only facilitates regulatory authorities to verify the source of works, but also provides a technical basis for copyright disputes. For example, where an AI-generated virtual scene is illegally misappropriated, the implicit identifier can quickly lock in the liable subject, thus protecting the legitimate rights and interests of original creators.

In addition, the *Measures for the Labeling of AI-Generated Content* compels platforms and content creators to improve their technological compliance. Film and television communication platforms shall upgrade their review systems to automatically identify unlabeled AI content and add reminder labels. This drives platforms to invest more resources in the development of intelligent detection tools and promotes the unification of technical standards for the industry. For creators, they may face the problem that labeling affects artistic expression at the initial stage, but in the long run, clear rules will instead stimulate legitimate innovation. For example, on the premise of lawful labeling, new forms such as AI-assisted script generation and virtual actors can be explored.

It is worth noting that the new regulations pose challenges to cross-border content dissemination. The international distribution of film and television works requires coordination of identification standards among different jurisdictions, which obliges the industry to establish a transnational cooperation mechanism, and the global compatibility of implicit identification will become the key focus of technological breakthroughs.

Overall, *The Identification Measures* has built a "safe zone" for AI applications in the film and television industry through the dual path of technical constraints and institutional norms. It not only prevents risks of technology abuse, but also reserves space for innovation, and may push China's film and television industry into a new stage where intelligentization and standardization develop in parallel.

2. Original Text of Laws and Regulations

Notice on Issuing the Measures for the Labeling of Artificial Intelligence Generated and Synthesized Content

Circular No. 2 [2025] of the Cyberspace Administration of China

To Cyberspace Administrations, Communications Administrations, Public Security Departments (Bureaus) and Radio and Television Administrations of all provinces, autonomous regions and municipalities directly under the Central Government; Cyberspace Administration, Bureau of Industry and Information Technology, Public Security Bureau, and Bureau of Culture, Sports, Radio, Television and Tourism of Xinjiang Production and Construction Corps:

For the purposes of promoting the sound development of artificial intelligence, standardizing the labeling of AI-generated synthetic content, protecting the lawful rights and interests of citizens, legal persons and other organizations, and safeguarding public interests, the Cyberspace Administration of China, the Ministry of Industry and Information Technology, the Ministry of Public Security, and the National Radio and Television Administration have formulated the *Measures for the Labeling of Artificial Intelligence-Generated Synthetic Content*, which is hereby issued to you for earnest compliance and implementation.

Cyberspace Administration of China

Ministry of Industry and Information Technology of China

Ministry of Public Security of the People's Republic of China

National Radio and Television Administration

March 7, 2025

Measures for the Labeling of Artificial Intelligence-Generated and Synthetic Content

Article 1 For the purposes of promoting the sound development of artificial intelligence, standardizing the identification of artificial intelligence-generated and synthetic content, protecting the legitimate rights and interests of citizens, legal persons and other organizations, and safeguarding public interests, these Measures are hereby formulated in accordance with laws, administrative regulations and departmental rules including the *Cyber Security Law of the People's Republic of China*, *Provisions on the Administration of Algorithmic Recommendation Services for Internet Information Services*, *Provisions on the Administration of Deep Synthesis Services for Internet Information Services*, and *Interim Measures for the Administration of Generative Artificial Intelligence Services*.

Article 2 These Measures shall apply to the activities of labeling artificial intelligence-generated and synthesized content carried out by Internet information service providers (hereinafter referred to as "service providers") that meet the circumstances specified in the *Provisions on the Administration of Algorithmic Recommendation Services for Internet Information Services*, *Provisions on the Administration of Deep Synthesis for Internet Information Services* and *Interim Measures for the Administration of Generative Artificial Intelligence Services*.

Article 3 AI-generated and synthesized content refers to such information as texts, images, audio recordings, video recordings, virtual scenes and the like, which is generated or synthesized by utilizing artificial intelligence technologies.

Markers of AI-generated synthetic content include explicit markers and implicit markers.

Explicit identifier means an identifier that is added to generated synthetic content or the interface of an interactive scenario, presented in such forms as text, sound, graphics and others, and can be clearly perceived by users.

An implicit mark refers to a mark that is added to the file data of generated synthetic content by means of technical measures and is not readily perceptible to users.

Article 4 Where the generative synthesis services provided by a service provider fall under the circumstances specified in Paragraph 1 of Article 17 of the *Regulations on the Administration of Deep Synthesis Internet Information Services*, the service provider shall affix explicit marks to the generative synthesis content in accordance with the following requirements:

(I) Add marks such as text prompts or general symbol prompts at the beginning, end or appropriate position in the middle of the text, or add conspicuous prompt marks on interfaces of interactive scenarios and around the text.

(2) Add marks such as voice prompts or audio rhythm prompts at the beginning, end or appropriate position in the middle of the audio, or add prominent prompt marks on the interface of interactive scenarios;

(III) A conspicuous prompt mark shall be added at an appropriate position of the image.

(IV) Conspicuous prompt signs shall be affixed to the initial frame of the video and appropriate positions around the video playback area; such conspicuous prompt signs may also be affixed to appropriate positions in the middle and at the end of the video.

(V) Where a virtual scene is presented, a conspicuous prompt mark shall be displayed at an appropriate position on the initial screen; a conspicuous prompt mark may be displayed at an appropriate position during the continuous service process of the virtual scene.

(VI) Other generative and synthetic service scenarios shall affix prominent prompt markings in light of their respective application characteristics.

When service providers provide functions such as downloading, copying and exporting of generated synthetic content, they shall ensure that the documents contain the required explicit markings._GB2312;color:rgb(8,15,23);font-size:12.0000pt;">

Article 5 A service provider shall, in accordance with the provisions of Article 16 of the *Regulations on the Administration of Deep Synthesis Internet Information Services*, add implicit identifiers to the file metadata of generated synthetic content. Implicit identifiers shall include production element information such as attribute information of generated synthetic content, name or code of the service provider, and content number.

Service providers are encouraged to embed implicit identifiers such as digital watermarks into the synthetic content they generate.

File metadata refers to the descriptive information embedded in the header of a file in accordance with specific encoding formats, which is used to record information including the source, attributes and purpose of the file.

Article 6 Service providers engaged in online information content dissemination services shall take the following measures to standardize the dissemination activities of generated synthetic content:

(I) Verify whether implicit identifiers are contained in the file metadata. Where the file metadata explicitly marks the content as generated synthetic content, appropriate measures shall be taken to affix conspicuous prompt marks around the published content, so as to explicitly remind the public that the said content is generated synthetic content.

(II) Where no implicit identifier is found upon verification of the document metadata, but the user declares that the content is generated synthetic content, appropriate measures shall be taken to add conspicuous prompt signs around the published content to remind the public that such content may be generated synthetic content.

(III) Where no implicit identifier is found upon verification of the file metadata, and the user does not declare the content as generated and synthetic content, the content shall be identified as suspected generated and synthetic content if the service provider providing online information content dissemination services detects an explicit identifier or other traces of generation and synthesis. The service provider shall adopt appropriate methods to affix a conspicuous prompt label around the published content to remind the public that the content is suspected generated and synthetic content;

(IV) Provide necessary labeling functions, and remind users to proactively declare whether the content they publish contains generated and synthetic content.

Under any of the circumstances as provided in Items 1 to 3 of the preceding paragraph, such dissemination element information as the attribute information of generated synthetic content, the name or code of the dissemination platform, and the content number shall be added to the document metadata.

Article 7 When conducting the review for the listing or launch of Internet applications, Internet application distribution platforms shall require Internet application service providers to specify whether they provide artificial intelligence-generated synthetic services. Where an Internet application service provider provides artificial intelligence-generated synthetic services, the Internet application distribution platform shall verify the relevant materials concerning the labeling of its generated synthetic content.

Article 8 Service providers shall explicitly specify such specifications as the methods and formats for the labeling of generated synthetic content in user service agreements, and remind users to carefully read and understand the relevant labeling administration requirements.

Article 9 Where a user applies to a service provider for generated synthetic content without explicit markings, the service provider may, after expressly stipulating the user's marking obligations and usage liabilities in the user agreement, provide the aforesaid generated synthetic content without explicit markings, and shall retain relevant logs such as information of the service recipient pursuant to the law for no less than six months.

Article 10 Where a user publishes generated synthetic content by using online information content dissemination services, it shall proactively make a declaration and mark the said content via the marking function provided by the service provider.

No organization or individual shall maliciously delete, tamper with, forge or conceal the identifiers of generated and synthetic content specified in these Measures, nor provide tools or services for other parties to commit the aforesaid malicious acts, nor infringe upon the lawful rights and interests of others by resorting to improper identification-related means.

Article 11 Where a service provider carries out labeling activities, it shall also comply with the requirements of relevant laws, administrative regulations, departmental rules and mandatory national standards.

Article 12 When going through formalities such as algorithmic record-filing and security assessment, service providers shall, in accordance with these Measures, submit relevant materials concerning the identification of generated and synthetic content, strengthen the sharing of identification information, and provide support and assistance for the prevention and crackdown on relevant illegal and criminal activities.

Article 13 Whoever violates the provisions of these Measures shall be handled by relevant competent authorities such as those for cyberspace administration, telecommunications, public security and radio and television in accordance with their respective functions and duties and the provisions of relevant laws, administrative regulations and departmental rules.

Article 14 These Measures shall come into force as of September 1, 2025.