AI-looking product images and video need a clear deployer disclosure

If your store publishes AI-generated or heavily manipulated images or video that look real — lifestyle shots with a synthetic model, or a product demo that could pass as filmed footage — Article 50(4) of the EU AI Act makes you (the deployer) disclose that. Mark that it was artificially generated or manipulated, clearly and at first exposure.

That duty sits on top of Article 50(2), which pushes providers of generative systems to embed machine-readable marks. Per Commission guidance, a hidden watermark alone is not enough for your public-facing disclosure: shoppers need a visible or otherwise obvious label without hunting for technical signals. Creative or satirical uses get a lighter touch (disclose existence without spoiling the piece), but ordinary product marketing that resembles real people, places, or events generally does not.

Practical check: inventory generative assets on product pages and ads; add a clear “AI-generated” (or equivalent) label where Article 50(4) applies; and don’t assume your model vendor’s metadata covers your deployer duty.