It is my understanding that yes, affiliates (ie; secondary producers) are required to keep 2257 records for all explicit content that they are retransmitting.

Loosely speaking, explicit means sex, cum, cocks, balls, buttholes, tits, and pussies. The reality is a bit more complex than that. The law uses terms like "lascivious displays of the pubic region".

And when I say sex, that doesn't mean just shots that show penetration. The law has always said real sex requires IDs, but the new 2257 interpretation going into effect also states that it covers simulated sex as well. Meaning all those softcore images of a guy parked behind another guy's butts are illegal, even if you couldn't tell if the two were really fucking or not. If it's meant to suggest sex now, it's interpreted as actually being sex regardless or not whether that's what is going on.

At GayGeek we long ago made the choice of being strict on our choice of images that we display. Most other review sites have ignored 2257 laws and show explicit pictures. Some of those review sites are outside the USA, but I will be curious to see if the American ones make any changes in their approach.

--Aaron

PS, Most sponsors are totally understandable about the desire to run non-explicit images as well. If you ask them they're usually happy to let you pop inside their website to grab PG-rated images.