The Complete Guide to Content Review in China 

What is Content Review?

Content review is the process of systematically examining and evaluating digital content before it’s published or made available to users. This includes screening text, images, videos, audio files, and interactive elements to ensure they comply with local regulations, cultural standards, and platform policies. In China’s digital ecosystem, content review serves as a critical regulatory safeguard that determines whether content can be legally distributed to Chinese users.

Why Do I Need to Do Content Review for My Solution in China?

Content review is not optional in China; it’s a legal requirement that protects your product or app from suspension, removal from app stores, and potential legal consequences. Chinese regulations mandate that all digital content, including text, images, videos, audio, and social functions such as likes and comments, must comply with strict content standards.

Operating without proper content review can result in platform takedowns and app store removal, significant fines and administrative penalties, license revocation, and legal consequences for your business. This process protects AppInChina, our clients, and end-users by ensuring that all content complies with the full scope of Chinese regulations.

There are six key laws that lay the legal foundation for content review requirements in China’s tech ecosystem. These six laws highlight the importance of staying compliant through content review:

1. Cybersecurity Law of the PRC (中华人民共和国网络安全法, 2017)
   • Articles 12, 47, and 48 require internet service providers to prevent dissemination of prohibited content and assume responsibility for information security management.
   • Failure to do so may lead to suspension of services or administrative penalties.
2. Personal Information Protection Law (PIPL, 个人信息保护法, 2021)
   • Requires platforms to prevent illegal collection, use, or disclosure of personal data, especially within user-submitted content.
3. Data Security Law (数据安全法, 2021)
   • Obligates companies to conduct risk monitoring and security assessments for data handling and public content distribution.
4. Administrative Provisions on Internet Comment Threading Services (互联网跟帖评论服务管理规定, 2017)
   • Platforms must review and manage user-generated content (UGC) before publication, assign content moderators, and retain data logs for six months.
   • Article 5 mandates real-name user identification, and Article 10 requires pre-screening of sensitive comments.
5. Provisions on the Governance of the Online Information Content Ecosystem (网络信息内容生态治理规定, 2020)
   • Reinforces the duty of online platforms to promote “positive” content and eliminate harmful, false, or illegal content.
6. Administrative Measures for Internet Information Services (互联网信息服务管理办法, 2011)
   • Requires internet content providers to obtain necessary approvals for publishing or distributing content online and to report illegal content promptly.
     

What Types of Content Require Review?

There are three distinct types of content, each with specific review processes that must be followed to ensure compliance.

User-Generated Content (UGC) includes posts, comments, reviews, and forum discussions created by your solution’s end-users. This content must be filtered using a Content Review API before publication, and this requirement is mandatory – failure to implement the API before public release may result in termination of your company’s publishing agreement with AppInChina.

Developer-Generated Content (DGC) encompasses content created by your development team for publication in China. This content, including both the initial content that is published in China and any future updates, should be reviewed in order to minimize any compliance and/or public relations risks to your company in China. We recommend using a Content Review API to check this content, but if this is not feasible, then AppInChina can also review the content manually.

Customer-Generated Content (CGC) is content that is created by your company’s customers for display in China. This is usually only applicable to B2B SaaS platforms where customers have their own content that they deliver through your company’s platform. While not mandatory, we recommend that this content be reviewed through a Content Review API and/or manual review in order to prevent any risks to your customers and your solution in China.

What if My Solution Has Social Functions?

If your solution includes social features such as comments, replies, messages, likes, posting, or reposting, you must integrate an identifiable login solution. Acceptable forms of identification include mobile phone numbers, Chinese ID card numbers, or social security numbers.

Chinese law mandates real-name verification for all solutions offering social or interactive features to ensure user accountability and content traceability. This requirement stems from the Cybersecurity Law of the PRC, Article 24, which requires platforms to verify users’ real identity before allowing access to publishing or interactive functions.

Additionally, apps or products with social functions must include a reporting mechanism, as required by Chinese regulations governing online platforms.

What Solutions Are Available for Content Review?

AppInChina recommends the Alibaba Cloud Content Moderation API for its high detection accuracy across all content types, including text, images, videos, and audio content.

Content is flagged with specific risk levels to help you understand what action is required. Content marked as “Without risk” is safe to publish immediately. Content flagged as “Low,” “Medium,” or “High” risk requires manual review by AppInChina, with specific labels indicating the reason for the assigned risk level.

The API flags content but doesn’t block it automatically, meaning your company must ensure that any content isn’t published until it has been verified as compliant.

How Can I Integrate Content Review Into My Solution?

We offer two primary integration options to accommodate different technical preferences and capabilities.

Option 1: Public URLs to AppInChina allows you to store content in China-accessible storage such as AWS S3 or a CDN, then provide public URLs in our specified format. AppInChina will run this content through the Content Review API, with results appearing in our admin dashboard. We will then conduct a manual review of any flagged content, and any content that fails the manual review must be either edited by your team and retested or directly removed.

Option 2: Direct API Integration involves AppInChina creating a limited Alibaba Cloud China account for your team, allowing you to integrate directly with the Content Review API. AppInChina receives read access to verify results and manually reviews flagged content, providing written confirmation of what needs to be changed.

Both solutions ensure that content is properly screened before publication and that you maintain compliance with Chinese regulations throughout the operation of your solution in China.

How Much Does Content Review Cost?

Content review costs vary based on content volume and review type. Here is an example cost breakdown for reviewing a single 30-minute video:

• Video Image Review (one frame every 5 seconds): CNY 0.54 (360 frames x CNY 0.0015 per frame)
• Audio Review: CNY 0.675 (prorated for 30 minutes)
• Subtitle Review: CNY 0.0375 (7,500 characters x CNY 0.000005 per character)
• Total: CNY 1.34

The cost of manual review by AppInChina varies according to the volume of review work required.

Are There Alternative Cloud Providers?

While we recommend Alibaba Cloud China’s Content Moderation API, we understand that you may prefer to work with another provider. Other popular providers include:

• Tencent
• Azure China
• Baidu
• Huawei
• Volcano Engine

Each provider offers content moderation capabilities, though features and pricing may vary. AppInChina can help you evaluate which option best fits your existing infrastructure and compliance needs.

How Is My Data and IP Protected During Content Review?

Alibaba Cloud’s terms of service clearly state that any content that is checked using their Content Review API will be protected as follows:

• 3.2.2 Without your consent, Alibaba Cloud will not use or disclose your information or data to any third party, except in the following circumstances:

• 3.2.2.1 For the purpose of serving users, Alibaba Cloud may use your data to provide services to you, including but not limited to sending you information about products and services or monitoring your data and service usage behaviour to provide you with Cloud Shield services.

• 3.2.2.2 Disclosure to third parties or administrative or judicial authorities as required by relevant laws and regulations, or at the request of administrative or judicial authorities.

• 3.2.2.3 If you violate relevant Chinese laws and regulations, disclosure to a third party may be necessary for them to assert their rights against you.

• 3.2.2.4 Sharing with third parties that you have acknowledged for the purpose of providing the software or services you have requested. 

How Do I Get Started with Content Review?

Ready to implement content review for your app or solution in China? Contact us to assess your specific content review needs, choose the right integration solution, set up your Content Review API, and ensure full compliance with Chinese regulations.

Our team will work with you to understand your solution’s content types, user interactions, and technical requirements to create a customised content review strategy.