Labeling of AI-generated and synthesized content

How do I apply explicit labels to images, videos and virtual scenes?

What you may need to do

1. Images: add a conspicuous notice at a fixed position on the frame, so that it cannot be cropped or covered.
2. Video: the opening frame must carry the notice, and it stays visible around the player.
3. Virtual scenes: label the opening frame, and consider a notice during continued service.
4. Write the label position into your asset templates so that operators cannot miss it when adding labels by hand.

Provisions relied on

One-line conclusion

Images need a conspicuous notice at a suitable position; for video, the opening frame and the area around the player need a conspicuous notice, and further notices may be added at suitable positions at the end and in the middle; where a virtual scene is presented, the opening frame needs a conspicuous notice, and one may be added at a suitable position during continued service. The keywords in the requirement are conspicuous and suitable position.

Basis

Article 4 sets requirements for these three formats separately:

Images — (3) add a conspicuous notice at a suitable position on the image.

Video — (4) add a conspicuous notice at a suitable position on the opening frame of the video and around where the video plays; additional conspicuous notices may be added at suitable positions at the end and in the middle of the video. The opening frame and the area around the player are what shall be done; the end and the middle are optional additions.

Virtual scenes — (5) when presenting a virtual scene, add a conspicuous notice at a suitable position on the opening frame; a conspicuous notice may be added at a suitable position during the continued provision of the virtual scene.

Note the premise these clauses rest on: the generative service offered by the service provider falls within the circumstances in Article 17, paragraph 1 of the Provisions on the Administration of Deep Synthesis of Internet Information Services (互联网信息服务深度合成管理规定).

What you need to do

Images: fix one standard label position (for example a fixed corner inside the frame), carry it in the image-generation template, and test whether it is still visible after cropping, adding a sticker, or scaling.

Video: the notice must appear on the opening frame; keep it resident around the player (title bar, playback page information area) rather than only stamping a corner mark inside the video that can be cut off.

Virtual scenes and digital humans: show the notice on the opening frame when the user enters the scene; keep the notice during continued service as appropriate.

Make labelling an asset quality-check item and specify who checks at which step, so that a missing label is not discovered only just before release.

For video files users can download, also check that the explicit label is still present inside the file.

Common pitfalls

Putting the label only on the last frame: a user who swipes away after the opening never sees a notice.

Placing the notice in a web page area outside the frame: once the file is downloaded or forwarded, the label disappears entirely.

The label covered by other elements, or set to very low opacity, does not amount to conspicuous.

Labelling only vertical assets, while horizontal formats and grid cover images are missed.

For virtual scenes, showing the notice only on the loading page and nothing once the user is inside full screen.

Common follow-up questions

Q: Is it acceptable to skip the middle and the end of a video?

A: The clause uses may for the middle and the end of a video; the opening frame and the area around the player fall within what shall be added.

Q: Is a very small AI corner mark on an image enough?

A: The clause requires a conspicuous notice. The test is whether the user can clearly perceive it, and anything too small, too faint or covered is not safe.

Common follow-up questions

Should cover images be labelled separately?

A cover image is content in image form, so assess it under Article 4, item (3) and add a conspicuous notice at a suitable position.

Can the virtual-scene notice sit on the loading page?

The clause says a suitable position on the opening frame; whether a loading page counts as the opening frame is open to interpretation, so we suggest giving the notice on the opening frame itself as well.

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