Eu Ai Act Product Image Labels

An AI-edited product image can involve two different disclosure duties. Sourceful's Riverflow article distinguishes machine-readable marking from a disclosure the customer can perceive. Article 50 generally requires providers of generative systems to make their outputs detectable, subject to exceptions, while professional users have separate disclosure duties for content that constitutes a deepfake.

The European Commission's guidance explains that the deepfake assessment includes whether content falsely appears authentic, considering its context and audience. For product marketing, the relevant issue is what an image leads people to believe about the product or depicted event. The amount of AI editing alone does not settle whether visible disclosure is required.