China's Measures for Labeling of AI-Generated Synthetic Content has been in force for nearly a year, with mandatory national standard GB 45438 alongside it - yet many creators and teams still operate on "I know I should label, I don't know how." Our previous AI Watermark Arms Race Hotspot covered the red-line risk of label-stripping tools; this SOP covers the correct posture: three steps to give your AI content a compliant ID card - an explicit label users can see, an implicit label machines can read, and a platform declaration that stays on record. Fully actionable; commands come from official documentation.
Scope note: this is a technical workflow plus public regulation summary, not legal advice; for specific scenarios (especially commercial publishing, cross-border distribution) consult a professional. Commands per the official c2patool docs.
1. Step One: Decide Whether Your Content Needs Labeling
The Measures cover AI-generated or synthesized text, images, audio, video, virtual scenes, and other information. A quick three-question self-check:
- Who generated it: was the content (in whole or substantial part) generated/synthesized by an AI model, or did AI only fix typos and grammar? The latter generally falls outside labeling scope.
- Deep-synthesis situations: face/voice replacement, scene synthesis, immersive scenes and similar deep-synthesis content carry stricter explicit-labeling requirements.
- Who publishes it: are you a service provider (platform/tool maker) or a user (an individual/team creating with tools)? Provider obligations are heavier (label + verify); users also have a proactive declaration duty (Article 10).
When in doubt, label - the cost of over-labeling is one line of notice; the cost of missing labels is compliance risk.
2. Step Two: Add the Explicit Label (User-Perceivable)
The explicit label must be directly visible/audible to ordinary users as they consume the content. By content type:
| Content type | Explicit label practice (per Article 4 requirements) |
|---|---|
| Text | Written notice at the start/end of the article (e.g., "This article was AI-assisted"), or a conspicuous notice in the interface |
| Image | Marking at a conspicuous position on the image |
| Audio | Voice or audio cue notice at the beginning/end |
| Video | Conspicuous marking on the opening screen |
Practical points: put the notice conspicuously at the start or end, not buried in paragraph three; use the publishing platform's built-in "AI-generated" declaration toggle (major platforms provide one per the Measures) - the platform attaches a unified label, which is steadier than pasting your own line.
3. Step Three: Add the Implicit Label (Machine-Readable)
The implicit label goes into file metadata - the channel platforms verify and you prove provenance with. The handiest tool for images/videos/documents is the official C2PA CLI c2patool (contentauth/c2pa-rs, Rust, actively maintained):
1) Install (any one):
# macOS
brew install c2patool
# Generic (needs a Rust toolchain)
cargo install c2patool
# Or download a prebuilt binary from GitHub Releases2) Write the manifest definition (manifest.json, declaring trained-algorithmic media):
{
"declare": {
"c2pa.created": "auto",
"c2pa.actions": [
{ "action": "c2pa.created", "digitalSourceType": "trainedAlgorithmicMedia" }
]
},
"vendor": "your-team",
"claim_generator": "your-workflow/1.0"
}Fields per the official manifest docs; trainedAlgorithmicMedia is the IPTC digital source type standard value for "AI-generated media."
3) Embed and verify:
# Embed: read the original image, add the manifest, output a labeled file
c2patool image.jpg -m manifest.json -o image_labeled.jpg
# Verify: confirm the label is present and the signature valid
c2patool image_labeled.jpg -dThe -d flag prints the detailed manifest report; confirm the digitalSourceType assertion landed and the implicit label is done. Wrap in a shell loop for batches; teams building their own AI services should go further and watermark model outputs (see our SynthID-Text Teardown).
4. Step Four: Publish and Keep Records
- Platform declaration: tick the platform's "AI-generated" declaration when publishing (it pairs with the explicit label; the platform verifies the metadata implicit label).
- Keep evidence: retain the manifest file and a screenshot of the
c2patool -doutput; for outsourcing/collaboration, write labeling cooperation duties into the delivery agreement. - Verify incoming work: run
c2patool <file> -don outsourced manuscripts to look for AI-source assertions; cross-check with statistical detection (see our AI Content Detector Tools Compared).
5. Five Common Pitfalls
- Platform re-compression strips metadata: transcoding on WeChat/Weibo distribution chains can strip C2PA data. The explicit label (the line baked into the image) is the final backstop - don't do just one of the two.
- Never "clean" content with label-stripping tools before publishing: Article 10 forbids maliciously deleting, altering, fabricating, or concealing labels - and forbids providing such tools. Stripping is not only unlawful; technically it doesn't even work (statistical watermark residue remains).
- Explicit label hidden too deep: end-of-article fine print, a 4px corner mark, or 0.5 seconds at the video's end do not count as "conspicuous." Judge by "visible at first glance."
- Assuming a watermark is enough: watermarks are only one encouraged form of implicit label; explicit labels and metadata labels are independent obligations - none substitutes for another.
- No written terms for outsourced work: if the contractor used AI but didn't label, responsibility gets murky. Put "AI-use disclosure + labeling cooperation" clauses in the contract and verify at delivery.
Frequently Asked Questions
Q1: I only used AI to polish my own writing - do I need to label? A1: Generally no - the Measures target AI-generated synthetic content; pure assistance (typos, grammar) usually doesn't qualify. The test is "whether a substantial part was generated by AI." When unsure, add a line of "AI-assisted" notice; over-labeling is harmless.
Q2: Can I choose between explicit and implicit labels? A2: No - they are parallel obligations. The explicit label is for humans (text/image/audio notice); the implicit label is for machines (metadata/watermarks). Implicit-only leaves users uninformed; explicit-only breaks platform verification and provenance chains.
Q3: Can a c2patool-embedded label be stripped? A3: The metadata segment can be peeled off (open-source tools have demonstrated this), but C2PA also has "soft binding" mechanisms that chain credentials to the content itself - stripping is not clearing. For compliance, the point is: your labeling fulfills your duty; someone else stripping it is their legal risk.
Q4: Do individual creators / self-media fall under these Measures? A4: Yes. Users publishing AI-generated content via platforms should proactively declare and use platform labeling functions (Article 10); platforms carry verification and supplementary-labeling duties. The easiest routine for individual authors: platform declaration toggle + explicit notice line, plus c2patool implicit labels for images.
Q5: Does publishing abroad follow the Chinese standard? A5: Services reaching mainland audiences fall under the Measures; the EU AI Act has its own transparency duties. C2PA is an international standard format - embed once, usable across jurisdictions. For cross-border compliance boundaries, consult a professional.
References
- CAC and three other departments: Measures for Labeling of AI-Generated Synthetic Content (published 2025-03-14, effective 2025-09-01; Article 3 explicit/implicit definitions, Article 4 explicit requirements, Article 5 implicit requirements, Article 10 proactive declaration and no-stripping clause)
- Mandatory national standard: GB 45438 (AI-generated synthetic content labeling)
- GitHub: contentauth/c2pa-rs (official c2patool docs:
-membed,-ddetailed report,--create trainedAlgorithmicMedia, manifest definition) - IPTC NewsCodes: digitalSourceType (trainedAlgorithmicMedia standard value)
- This site: AI Watermark Arms Race Hotspot | SynthID-Text Teardown | AI Content Detector Tools Compared
Compiled from public regulations and official tool documentation (2026-08-17), not legal advice; commands and fields per the official c2patool docs.