EU AI icon on video: burn it in, do not rely on a platform badge

EU icon guidance says the label must be embedded in the video and kept on reshare or download. A burned-in overlay does that; a platform badge does not.

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If you use the EU AI icon on video, burn it into the frames. The Commission's icon page says that for video the icon should be embedded directly in the content and kept when the content is reshared or downloaded. A badge that a platform draws around your video is not part of the file, so a downloaded copy would not carry it. In Sume, a compose overlay re-renders the clip into a new MP4 with the icon inside the picture.

What the Commission pages say

Two pages matter: the icon page (updated September 24, 2026) and the Article 50 FAQ.

EU icon and Article 50 facts, read 2026-10-05
TopicStatement
Video iconClearly visible at first exposure, embedded directly in the content, kept when reshared or downloaded, placed so no overlay obstructs it
Icon useOptional; Article 50 duties remain mandatory; the icon alone does not establish compliance
Article 50 startApplies from August 2, 2026
Marking grace periodTo December 2, 2026, only for marking and detection (50(2)) of systems placed on the market before August 2
DeployersDisclose deepfakes at first exposure at the latest, clear and distinguishable, visible or audible without special tools
Creative worksArtistic, creative, satirical or fictional works need only appropriate disclosure
FinesUp to EUR 15M or 3% of worldwide turnover

Why burned-in beats a badge

A platform label sits in the app's interface. If someone saves the video and posts it elsewhere, the label does not travel. A burned-in icon is in every frame it covers, so it survives a download. That is the property the guidance describes.

The cost is that the burn-in is permanent in that file. Keep an unlabelled master and publish the labelled copy. Using Timeline compose with operation: "overlay" produces a new artifact; the source is not changed. The job is $0.02 flat per the docs.

Practical rules

  • Show the icon from the first frame, since the guidance says first exposure.
  • Overlay duration follows the video layer: the still stays for the whole clip.
  • Re-encode after overlay is a new file; re-share that one.
  • Do not treat the icon as a compliance certificate. The page says it is not.
  • For legal questions about your case, ask counsel; this post only restates the pages above.

Sources

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