China's Deep Synthesis Rules and AI Content Labeling

The Provisions on the Administration of Deep Synthesis Internet Information Services were issued in late 2022 by the Cyberspace Administration of China (CAC), the Ministry of Industry and Information Technology and the Ministry of Public Security, and took effect on January 10, 2023. They define deep synthesis broadly as technology that uses deep learning or virtual reality to generate or edit text, images, audio, video or virtual scenes. Providers must verify users' real identities, set management rules, review content, and keep mechanisms for dispelling rumors. When they offer tools for editing biometric information such as a face or voice, they must prompt users to obtain the separate consent of the person being edited. They must also file their algorithms with the CAC. Content that could confuse or mislead the public, such as synthetic faces, cloned voices or realistic scenes, must carry a conspicuous label, and no one may remove or conceal these labels. The 2025 Labeling Measures, issued by the CAC with three other agencies and accompanied by a mandatory national standard, GB 45438-2025, make labeling more specific. Explicit labels are visible or audible cues such as text notices, audio prompts or graphic marks. Implicit labels are embedded in file metadata and include information such as the provider's name and a content ID. Distribution platforms must check uploads for metadata. They display a notice when AI generation is confirmed, and they apply possible or suspected labels when the user declares it or detection suggests it. App stores must check that apps comply. Western approaches are narrower or newer. The EU AI Act's Article 50 imposes transparency and marking duties on AI-generated content and deepfakes, but they apply later than China's. In the United States, deepfake rules are mostly state laws on election ads and intimate imagery, while standards such as C2PA content credentials are voluntary. Labels do not solve detection: metadata can be stripped by screenshots or re-encoding, which is why China layers platform detection and user declarations on top.