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Guide

Labelling AI-Generated Product Photos and Descriptions

AI Act

Artificial intelligence has quietly become part of everyday online retail. Shops generate product imagery, write descriptions, and answer customer questions with AI tools. The EU AI Act, Regulation (EU) 2024/1689, brings transparency duties that touch all three of these uses. This guide explains what Article 50 asks of an online shop and how to label AI-generated content so your customers are not misled.

Are you a deployer under the AI Act?

Most shops do not build their own AI models. They use third-party tools to generate an image, draft a description or power a chatbot. In the language of the AI Act, using an AI system in the course of your business makes you a deployer, and deployers carry the Article 50 transparency duties for the content and interactions they put in front of customers. In other words, buying the tool does not outsource the duty to disclose. You can read our summary on the AI Act law page and the fuller complete AI Act guide.

What Article 50 requires

Article 50 sets out several transparency duties that map neatly onto shop scenarios:

  • Tell users when they are interacting with an AI system rather than a person, for example a support chatbot.
  • Mark AI-generated or manipulated image, audio and video content as artificially generated.
  • Disclose AI-generated or manipulated text where it informs the public on matters of public interest, and disclose deep fakes.

The disclosures should be clear and given at the right moment: when the customer starts chatting, or when they view the content in question. Burying a single line in your terms and conditions is not the spirit of the rule.

AI-generated product photos

Synthetic imagery is where shops most often stray. If you use AI to create a lifestyle scene, place a product in a setting it was never photographed in, or generate a model wearing your item, that image is artificially generated and falls within the marking duty for synthetic visual content. Label it plainly, for example with a visible caption such as “AI-generated image”, so a shopper is not led to believe they are seeing a genuine photograph of the actual product.

Beyond the AI Act, misleading imagery can also raise separate consumer-protection concerns, so accurate labelling protects you on more than one front. If the picture materially changes what the customer thinks they are buying, transparency is not optional politeness, it is the point.

AI-written product descriptions

Text is more nuanced. The Article 50 text-marking duty is framed around AI-generated text that informs the public on matters of public interest, which a straightforward product description usually is not. That means the strict marking obligation frequently will not attach to ordinary catalogue copy. Even so, the safer and more customer-friendly approach is to keep AI-drafted descriptions accurate, review them before publishing, and avoid presenting machine-written claims as tested human judgement.

Where AI copy strays into areas the public relies on as information, or where you are unsure, a brief disclosure costs little and removes the risk. We cover the chatbot side of this in our FAQ on AI transparency for online stores.

Chatbots and customer interactions

If a shopper lands in a chat window staffed by AI, tell them so. A short line such as “You are chatting with an automated assistant” at the start of the conversation satisfies the interaction-disclosure duty and sets honest expectations. If a human takes over later, it is good practice to say that too.

A practical labelling checklist

  • Add a visible “AI-generated image” caption to any synthetic product photo.
  • Announce chatbot interactions up front, in plain language.
  • Review AI-drafted descriptions for accuracy before they go live.
  • Keep a note of which listings use AI content, so you can update labels consistently.

Transparency is cheap and trust is expensive. Telling customers what is AI-made costs a caption and buys you credibility.

This article is educational and does not constitute legal advice.