AI-generated content labeling

What Is an Implicit Label? What Goes in File Metadata?

What you may need to do

1. Write the metadata during generation, not as a patch-up at the publishing end
2. Cover at least the content attribute, the provider name or code, and the content number
3. Assess whether to add stronger measures such as digital watermarks, with priority for video and audio products
4. Turn the metadata fields and the writing logic into a technical specification and re-test after transcoding

Clause basis

One-line conclusion

An implicit label is "a label added by technical means to the file data of generated or synthesized content that is not readily perceived by users". A service provider must, as required by Article 16 of the Provisions on the Administration of Deep Synthesis of Internet Information Services, add an implicit label to the file metadata of generated or synthesized content, and the label content includes production-element information such as the attribute of the generated or synthesized content, the provider's name or code, and the content number; the Measures also encourage adding implicit labels in forms such as digital watermarks.

Basis

Article 5: "In accordance with Article 16 of the Provisions on the Administration of Deep Synthesis of Internet Information Services, a service provider shall add implicit labels to the file metadata of generated or synthesized content; implicit labels include production-element information such as the attribute of the generated or synthesized content, the provider's name or code, and the content number."

The second paragraph of the same article: "Service providers are encouraged to add implicit labels in forms such as digital watermarks to generated or synthesized content." Note the wording — "shall" for metadata, "encouraged" for watermarks — so the two do not carry the same weight.

The third paragraph of the same article gives the definition of metadata: "File metadata means descriptive information embedded in the file header in a specific encoding format, used to record information such as the source, attributes and purpose of a file."

What you need to do

Put metadata writing at the generation stage, not as a patch-up at publishing or upload time — only the generating side knows the content's true attributes and number.

The metadata fields must cover at least three kinds of production elements: the content attribute (whether it is generated or synthesized content), the provider's name or code, and the content number.

For file types that are easily re-edited, such as video and audio, assess whether to add enhancement measures such as digital watermarks.

After compression, transcoding, editing or splicing, re-test whether the metadata is still present, and write this into your test cases.

Document the field definitions so they can be explained when a distribution platform, a dissemination platform or a competent authority verifies them.

Common pitfalls

Doing only a watermark and no metadata. What the clause clearly requires is metadata; a watermark is an encouragement item, and the two cannot substitute for each other.

Marking only in the API response outside the file while the file itself carries no metadata, so once the user downloads it the label is entirely lost.

Second-editing tools stripping metadata by default, so downstream platforms cannot verify it.

Treating a file name such as "report_AI_version" as an implicit label; that is not a technical measure embedded in the file data.

Leaving metadata fields empty or filling them with marketing copy, with no verifiable number or provider name or code.

Common follow-up questions

Q: Is there a uniform rule for the specific metadata field format?

A: What the Measures list is the element content; conducting labeling activities must also meet the requirements of relevant laws, administrative regulations, departmental rules and mandatory national standards (Article 11), so implementation has to be checked against the corresponding standards.

Q: I use a third-party generation model — who writes the metadata?

A: Article 5 places the requirement on the service provider; the caller still has to ensure that the file finally provided to users carries a compliant implicit label, with responsibility divided as agreed in the contract and subject to the competent authority's determination.

Common follow-up questions

Is a watermark without metadata acceptable?

Not solid. What Article 5 requires is that an implicit label shall be added to file metadata; a watermark is an encouragement item.

Do chat products also need file metadata?

An implicit label targets the file data of generated or synthesized content; whether pure conversational text forms a file has to be judged against the actual product form.

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