Is Gemini API Free Tier allowed in EU Android apps using Bring Your Own Key (BYOK)?

Gemini API
1

Subject: Gemini API Free Tier in an Android BYOK application for EU users

I am developing Productos Gourmet, a free Android application that allows users to identify and analyze food products using Gemini API.

The application is designed so that each user creates their own free Gemini API key in Google AI Studio and enters it into the application.

Each user consumes only their own project’s quota. The developer does not share, sell, or distribute API keys.

The application is intended for adult users in Spain and the European Union.

Could you please clarify:

1. Is this Bring Your Own Key (BYOK) architecture permitted when each user has their own Free Tier project?

2. Does the EEA Paid Services requirement also apply when the developer does not provide the API key or pay for the requests?

3. If this is not permitted, is there any officially supported way to offer this functionality to European users without requiring a paid API account?

We would appreciate an explicit clarification before publishing the application.

2

Hello @roberto_macciocu ,

We can’t provide specific legal guidance on this forum. Please refer to the documents below:

3

Thank you for your response.

I understand that you cannot provide legal advice, but I am requesting clarification of Google’s own API usage policies.

My question is very specific:

Can a free Android application distributed in Spain allow each user to enter and use their own Gemini Free Tier API key, without the developer providing any API keys?

If this forum cannot provide an official answer, could you please direct me to the appropriate Google team or contact channel that can clarify this requirement?

I need to resolve this before publishing my application.

Thank you.

Un cordial saludo Roberto