EU AI icon: embedded in the video or a UI overlay, and when reshared
The Commission says the EU AI icon should be embedded in the content unless an equivalent like a UI overlay exists, and be visible on reshare or download.
Embedded in the video is the default. The Commission's EU Icons for labelling AI-generated content page says the icon "should be directly embedded into the deepfake or published text (except for creative works), unless equivalent alternatives are available such as a user interface overlay," and that it "must be visible when content is reshared or downloaded." A player overlay that disappears on download is therefore the weak option. The page calls its list a summary, not a complete overview, and points to Section 2 of the code for detail. This is not legal advice.
Why does reshare and download matter?
The page's rule is about the viewer's first exposure and later copies. It says the icon should be clearly perceivable and distinguishable at the latest at first exposure, and placed where no intervening overlay elements exist. The Commission FAQ separately says deployers cannot rely only on the machine-readable marking the provider embeds, because disclosure must be understandable without special tools. A label drawn by a web page does not travel with the MP4; one in the pixels does.
When is a UI overlay acceptable?
The page says equivalent alternatives such as an interface overlay are allowed where available, but it does not define "equivalent" in the summary. Because a download or a repost leaves your page behind, treat an overlay as acceptable only if you have confirmed it satisfies the code's placement section for your case.
| Point | What the page says |
|---|---|
| Timing | Perceivable and distinguishable at the latest at first exposure |
| Placement | Where no intervening overlay elements exist |
| Embedding | Directly embedded, unless an equivalent such as a UI overlay is available |
| Reshare and download | The icon must be visible |
| Creative works | Exception to the embedding rule |
How could the icon end up in an MP4 from Sume?
Sume's Timeline compose docs describe putting one Sume-hosted still and one Sume-hosted video on screen at the same time and returning one MP4. The docs do not mention the icon, its size or its timing, so check the result file yourself. Completed jobs return a media.sume.com artifact URL, per Jobs and results; publish that file, not a page that overlays the label.
Sources
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