November 2024
Introduction to the Measures for Labeling Artificial Intelligence Generated Synthetic Contents (Mainland China)
November 2024
Jolene Chen and Teresa Huang
Following the Cybersecurity Law of the People's Republic of China, the Administrative Provisions on Algorithm Recommendation for Internet-based Information Services, the Administrative Provisions on Deep Synthesis of Internet-based Information Services, the Interim Administrative Measures for Generative Artificial Intelligence Services, the Cyberspace Administration of China released the Measures for Labeling Artificial Intelligence Generated Synthetic Contents (Draft for Comment) (hereinafter referred to as the "Measures") on September 14, 2024. This article will provide a brief introduction to its content.
Firstly, Article 9 of the Administrative Provisions on Algorithm Recommendation for Internet-based Information Services, Article 16 of the Administrative Provisions on Deep Synthesis of Internet-based Information Services, and Article 12 of the Interim Administrative Measures for Generative Artificial Intelligence Services have already required service providers to label synthetic content generated by artificial intelligence. The present Measures further clarify the types and methods of labeling.
The Measures categorize the labeling of generated synthetic content into explicit labels and implicit labels. An explicit label refers to a label that is added in the interface for generated synthetic content or interactive scenes, and that is presented in the form of text, sound, graphics, etc., and can be obviously perceived by users. An implicit label refers to a label that is added by adopting technical measures for document data of generated synthetic content and is not easily perceived by users.
The Measures provide detailed enumerations of the methods for explicit labels according to different categories of generated synthetic contents, and also offer specific explanations regarding the methods for implicit labels and the descriptive information that needs to be labeled.
Furthermore, the Measures introduce obligations for service providers that provide platform services for the dissemination of network information to verify and label content.
For instance, through verification of implicit labels, acquisition of user declarations, or detection of explicit labels or other traces of generated synthetic contents, service providers should add prominent reminder labels to alert users that the content is confirmed, possibly, or suspected to be generated synthetic contents.
For content that is confirmed, possibly, or suspected to be generated synthetic, information such as the attributes of the generated synthetic content should be added to the document metadata, providing necessary labeling and reminding users to voluntarily declare whether the released content contains generated synthetic content.
Thirdly, the Measures add obligations for internet application distribution platforms to verify when an application is put on shelves or launched online for review, requiring them to verify whether service providers have provided labeling functions for generated synthetic content as required.
Fourthly, the Measures introduce methods for users to obtain generated synthetic content without explicit labels, as well as the labeling obligations for users when they subsequently upload generated synthetic content.
If users require service providers to provide generated synthetic content without any explicit labels, service providers may provide content without any explicit labels after specifying the users' labeling obligations and use responsibilities in the user agreement, and keep relevant logs for no less than six months. When uploading generated synthetic content to the service providers that provide network information content dissemination platform services, the users shall voluntarily make a declaration and use the labeling function provided by the platform to make labels.
The contents of all newsletters of Shanghai Lee, Tsai & Partners (Content) available on the webpage belong to and remain with Shanghai Lee, Tsai & Partners. All rights are reserved by Shanghai Lee, Tsai & Partners, and the Content may not be reproduced, downloaded, disseminated, published, or transferred in any form or by any means, except with the prior permission of Shanghai Lee, Tsai & Partners.
The Content is for informational purposes only and is not offered as legal or professional advice on any particular issue or case. The Content may not reflect the most current legal and regulatory developments. Shanghai Lee, Tsai & Partners and the editors do not guarantee the accuracy of the Content and expressly disclaim any and all liability to any person in respect of the consequences of anything done or permitted to be done or omitted to be done wholly or partly in reliance upon the whole or any part of the Content. The contributing authors' opinions do not represent the position of Shanghai Lee, Tsai & Partners. If the reader has any suggestions or questions, please do not hesitate to contact Shanghai Lee, Tsai & Partners.
Jolene Chen and Teresa Huang
Following the Cybersecurity Law of the People's Republic of China, the Administrative Provisions on Algorithm Recommendation for Internet-based Information Services, the Administrative Provisions on Deep Synthesis of Internet-based Information Services, the Interim Administrative Measures for Generative Artificial Intelligence Services, the Cyberspace Administration of China released the Measures for Labeling Artificial Intelligence Generated Synthetic Contents (Draft for Comment) (hereinafter referred to as the "Measures") on September 14, 2024. This article will provide a brief introduction to its content.
Firstly, Article 9 of the Administrative Provisions on Algorithm Recommendation for Internet-based Information Services, Article 16 of the Administrative Provisions on Deep Synthesis of Internet-based Information Services, and Article 12 of the Interim Administrative Measures for Generative Artificial Intelligence Services have already required service providers to label synthetic content generated by artificial intelligence. The present Measures further clarify the types and methods of labeling.
The Measures categorize the labeling of generated synthetic content into explicit labels and implicit labels. An explicit label refers to a label that is added in the interface for generated synthetic content or interactive scenes, and that is presented in the form of text, sound, graphics, etc., and can be obviously perceived by users. An implicit label refers to a label that is added by adopting technical measures for document data of generated synthetic content and is not easily perceived by users.
The Measures provide detailed enumerations of the methods for explicit labels according to different categories of generated synthetic contents, and also offer specific explanations regarding the methods for implicit labels and the descriptive information that needs to be labeled.
Furthermore, the Measures introduce obligations for service providers that provide platform services for the dissemination of network information to verify and label content.
For instance, through verification of implicit labels, acquisition of user declarations, or detection of explicit labels or other traces of generated synthetic contents, service providers should add prominent reminder labels to alert users that the content is confirmed, possibly, or suspected to be generated synthetic contents.
For content that is confirmed, possibly, or suspected to be generated synthetic, information such as the attributes of the generated synthetic content should be added to the document metadata, providing necessary labeling and reminding users to voluntarily declare whether the released content contains generated synthetic content.
Thirdly, the Measures add obligations for internet application distribution platforms to verify when an application is put on shelves or launched online for review, requiring them to verify whether service providers have provided labeling functions for generated synthetic content as required.
Fourthly, the Measures introduce methods for users to obtain generated synthetic content without explicit labels, as well as the labeling obligations for users when they subsequently upload generated synthetic content.
If users require service providers to provide generated synthetic content without any explicit labels, service providers may provide content without any explicit labels after specifying the users' labeling obligations and use responsibilities in the user agreement, and keep relevant logs for no less than six months. When uploading generated synthetic content to the service providers that provide network information content dissemination platform services, the users shall voluntarily make a declaration and use the labeling function provided by the platform to make labels.
The contents of all newsletters of Shanghai Lee, Tsai & Partners (Content) available on the webpage belong to and remain with Shanghai Lee, Tsai & Partners. All rights are reserved by Shanghai Lee, Tsai & Partners, and the Content may not be reproduced, downloaded, disseminated, published, or transferred in any form or by any means, except with the prior permission of Shanghai Lee, Tsai & Partners.
The Content is for informational purposes only and is not offered as legal or professional advice on any particular issue or case. The Content may not reflect the most current legal and regulatory developments. Shanghai Lee, Tsai & Partners and the editors do not guarantee the accuracy of the Content and expressly disclaim any and all liability to any person in respect of the consequences of anything done or permitted to be done or omitted to be done wholly or partly in reliance upon the whole or any part of the Content. The contributing authors' opinions do not represent the position of Shanghai Lee, Tsai & Partners. If the reader has any suggestions or questions, please do not hesitate to contact Shanghai Lee, Tsai & Partners.
