Shanghai Mandates Labeling for AI-Generated Outdoor Advertising Content

Shanghai's Market Supervision Administration has released new guidelines for outdoor advertising content, including specific requirements for advertising that utilizes artificial intelligence (AI). The directive, titled《上海市户外广告发布内容合规指引》(Shanghai Outdoor Advertising Content Compliance Guidelines), aims to clarify key risks and compliance requirements for advertisers.

The guidelines address common issues such as the prominence of text in advertisements, emphasizing that all notices must be true, clear, and conspicuous. Important transactional conditions and restrictive information must be presented fully and accurately. The use of superlative terms like "first," "original," "best," or "leading," as well as citations from other sources, is regulated to prevent misleading claims. A key new stipulation is that content generated by AI for advertising purposes must be legally identified as such.

Furthermore, the guidelines prohibit outdoor advertisements that harm national dignity or interests, disrupt social order, distort historical facts, or hurt national sentiment. They also restrict commercial promotion related to major political issues, historical events, or natural disasters. Certain types of advertisements, including those for specific medical services or products concerning sexual health and wellbeing, as well as funeral services, are banned from outdoor display.

To mitigate societal controversy, the regulations forbid the misuse of regional or gender labels for marketing purposes that could incite division or vulgarity. Emotional marketing tactics that amplify social anxieties or promote fan-based support campaigns are also restricted. The guidelines also focus on protecting minors and residents' living environments, particularly in residential areas like elevator interiors, by managing ad content and broadcast times. Advertisers, operators, and publishers are held responsible for content review and risk control.