China AI Plus Plan and AI Labeling Law

Summary

China has introduced a comprehensive dual approach to AI governance through its ambitious "AI Plus" plan paired with mandatory AI labeling legislation. This regulatory framework establishes China as a major player in structured AI governance, requiring all AI developers and service providers in Chinese jurisdiction to implement clear labeling systems and undergo mandatory ethics reviews. Unlike voluntary frameworks seen elsewhere, China's approach makes compliance non-negotiable, with specific requirements for fairness, accountability, and human dignity built into the legal structure.

The Dual-Track Strategy

China's approach uniquely combines promotional policy with regulatory control. The "AI Plus" plan signals the government's commitment to AI advancement across industries, while the labeling law ensures this growth happens within defined ethical boundaries. This dual-track strategy allows China to accelerate AI adoption while maintaining strict oversight—a balance that sets it apart from purely promotional or purely restrictive approaches in other jurisdictions.

The labeling requirements go beyond simple disclosure, creating a comprehensive identification system that makes AI use transparent to users and regulators alike. This visibility mechanism enables real-time monitoring of AI deployment across the Chinese market.

Mandatory Ethics Review: What It Actually Means

The legislation establishes two pathways for required ethics review:

Internal Organizational Review: Companies can develop their own ethics review processes, but these must meet government-defined standards covering the five core principles. Organizations choosing this route need documented procedures, qualified review personnel, and audit trails.

External Assessment: Third-party evaluation by approved assessment bodies. This option may be preferred by smaller companies lacking internal ethics expertise or by organizations seeking to demonstrate independence in their review process.

Both pathways require evidence of compliance with:

• Fairness in algorithmic decision-making
• Clear accountability structures
• Justice in outcomes and access
• Risk responsibility and mitigation
• Respect for life and human dignity

Who This Resource Is For

Primary audiences who must engage with this legislation:

• AI companies with operations, partnerships, or customer bases in China
• International technology firms planning market entry into China
• Legal and compliance teams managing cross-border AI deployments
• Ethics officers developing review processes for Chinese market compliance

Secondary audiences who should monitor this development:

• Policy researchers tracking global AI governance trends
• International regulators considering similar labeling approaches
• Business leaders evaluating China market strategies
• Academic researchers studying comparative AI policy

Implementation Roadmap

Immediate Actions (0-3 months):

• Audit current AI systems for labeling law coverage
• Identify which projects require ethics review
• Begin documenting existing ethical considerations in AI development

Short-term Compliance (3-6 months):

• Establish internal ethics review processes or identify external assessors
• Develop labeling protocols for AI systems
• Train relevant personnel on new requirements

Ongoing Compliance:

• Integrate ethics review into AI development lifecycle
• Maintain labeling system updates as AI systems evolve
• Monitor regulatory guidance and enforcement patterns

How This Compares Globally

China's mandatory labeling system is more prescriptive than the EU AI Act's transparency obligations and significantly more structured than the US's largely voluntary approach. The combination of promotional policy with strict compliance requirements creates a unique regulatory environment where AI innovation is encouraged but heavily channeled through government-defined ethical parameters.

The ethics review requirement resembles institutional review boards in academic research but applied to commercial AI development—a novel approach that other jurisdictions will likely study as they develop their own governance frameworks.