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Guide Label AI images: what the EU AI Act means for online shops.
Since 2 August 2026 the transparency obligations from Article 50 of the EU AI Act apply. Anyone who publishes AI generated images that show real people in a deceptively realistic way must disclose that they are artificially generated. For fashion shops using AI models we recommend a clear notice in the shop. This article is not legal advice.
What Article 50 sets out
- Providers of AI systems that generate images must mark the outputs as AI generated in a machine readable way. There is a transition period until 2 December 2026.
- Anyone who publishes AI content that depicts real people, places or events in a deceptively realistic way (deepfakes) must disclose this.
- The notice must be clearly visible, at the latest on first contact with the content.
What this means for AI product photos
AI models in product images show people who do not exist as such. Whether this falls under the deepfake rule in a given case has not yet been finally clarified. An open notice builds trust and avoids risks.
How to label in practice
- A line in the footer or on the product page, for example: "The people in our product photos are AI generated."
- A note in the captions or alt texts
- Preserve metadata in the image files
How we do it
On this website there is a note under every page stating that all people and product images are AI generated. For legally binding information please contact your legal counsel.
FAQFrequently asked questions
Do I have to label AI product photos?
For deceptively realistic depictions of people, Art. 50 EU AI Act requires disclosure. We recommend labelling AI images in the shop. If in doubt, seek legal advice.
Since when does the obligation apply?
The transparency obligations from Art. 50 have applied since 2 August 2026. For machine readable labelling by providers there is a period until 2 December 2026.
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