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Content Review Overview

As an essential part of compliance, content review is a regulatory safeguard that prevents the publication of sensitive, illegal, or politically risky content that could result in suspension of products, removal from app stores, or even legal consequences in China. This process protects AppInChina, our clients, and end-users by ensuring that all content—text, images, video, audio, and interactive elements (whether hard-coded or dynamically generated)—complies with the full scope of Chinese regulations.

To help you get started with Content Review integration, we recommend the following path:

  1. Understand the Requirements: Read this Overview to understand the types of content that need review and the legal requirements.
  2. Choose a Solution: Review the API Integration Guidelines guide to understand how to connect your backend to the Content Moderation API.
  3. Prepare Your Content: Follow the Tasks Submission Guide to format your content correctly for review.

Content review is mandated by the Cybersecurity Law of the PRC (2017). Articles 12, 47, and 48 require internet service providers to prevent the dissemination of prohibited content and assume responsibility for information security management. Failure to do so may lead to suspension of services or administrative penalties.

Content Types and Reviewing Processes

There are three main content types, each with distinct review processes:

1. User-Generated Content (UGC - Public)

This refers to public-facing content created by users that other people can see, such as social media posts, public forum comments, public reviews, or in-game public chats.

  • Why it matters: Because this content is broadcasted to the public, the Chinese government considers it high-risk for the dissemination of illegal or sensitive information.
  • Prerequisite (Real Identity Verification): If your solution includes social functions (e.g., comments, replies, posting), Chinese law (Cybersecurity Law, Article 24) requires you to verify the user's real identity before they can post. In China, this is typically achieved by requiring a Chinese mobile phone number during registration. For more information, please refer to our Login documentation.
  • Requirement: Must be filtered using a Content Review API before publication. Failure to implement the API before public release may result in agreement termination.
  • Process:
    1. Submission: A user attempts to post content.
    2. Automated Review: The content is immediately scanned by the Content Review API.
    3. Risk-Based Routing:
      • No Risk: The content is published immediately.
      • Low Risk: The content is published immediately to avoid disrupting the user experience, but it is simultaneously flagged for manual review by the AppInChina team. If the manual review confirms it violates regulations, it will be taken down.
      • Medium or High Risk: Publication is blocked. The content is held in a queue for manual review by the AppInChina team and will only be published if it is manually cleared.

2. Developer-Generated Content (DGC - Official)

This is the official, static content of the app or website itself, created by your team. It includes UI text, official articles, hardcoded images, marketing banners, and localization strings.

  • Requirement: Since you control this content and it doesn't change dynamically every second, it does not require a real-time API. Instead, it requires a one-time (or per-update) hybrid review: you first filter the content, and then AppInChina verifies the high-risk portions.
  • Process:
    1. Self-Assessment & Filtering: To ensure an efficient review process, you do not need to submit every single string of text in your app. Please apply common sense and filter out undoubtedly safe, standard UI elements (e.g., navigation bar labels like "Home" or "Settings", standard footers, basic button text).
    2. Identify High-Risk Content: Carefully review your remaining content against our Sensitive Topics Catalog. Any content touching on these areas must be isolated for our review.
    3. Formatting & Submission: Compile the filtered, potentially sensitive text into a CSV file for every language version of your solution. For images and videos, prepare them according to our Tasks Submission Guide. Submit these files to the AppInChina team.
    4. AppInChina Verification: Our compliance team will review the submitted high-risk content to ensure it adheres to Chinese regulations.
    5. Revisions (If Necessary): If any sensitive or non-compliant content is found, we will provide a detailed report. You must edit the flagged content and resubmit it for verification.
    6. Written Confirmation & Publication: Once the content is fully compliant, AppInChina will issue a formal written confirmation of legality, and you may proceed with publishing the update. Important: Publishing unverified high-risk DGC without prior written confirmation is a compliance violation.

3. Customer-Generated Content (CGC - Private)

This refers to private or inbound content sent from a user directly to your team or company, such as private customer support tickets, direct feedback forms, or private 1-on-1 messages to your business.

  • Why it matters: Because this content is not broadcasted to the public, the risk of mass dissemination of illegal content is very low. However, storing or processing illegal content on Chinese servers still carries inherent regulatory risks.
  • Requirement: While a strict pre-publication review is not legally mandated for private content, AppInChina highly recommends that CGC be reviewed using automated methods to ensure content safety and compliance. This protects your company, your support staff, and AppInChina from potential legal or reputational risks.
  • Process: You have two options for handling CGC:
    • Option A: Automated Review (Recommended)
      1. Integration: Connect your customer support or feedback channels to the Content Review API.
      2. Automated Scanning: The API scans incoming private messages in real-time.
      3. Internal Routing: Clean messages are routed to your support team normally. Flagged messages (Medium/High risk) can be blocked, redacted, or quarantined for internal review by your team, protecting your staff and servers from handling illegal content.
    • Option B: Formal Opt-Out
      1. Waiver: If you prefer not to implement API review for private inbound content, you must formally opt out by acknowledging the associated risks.
      2. Reactive Management: If legal issues arise from unmonitored CGC, AppInChina and your team will collaborate to address the concerns immediately. This may require retroactively introducing API-based or manual review processes to your support channels.