Not required under the guidelines, as long as the product then looks as it does in reality. AI-powered colour correction and re-scaling of images in product advertising are likely to have only a minor impact (para. 116). The guidelines list minor colour corrections, lightening, darkening, sharpening and noise reduction as standard editing (para. 92).
Labelling not required under the guidelines
The guidelines list minor colour correction, brightening, sharpening, cut-outs and filling borders as standard editing with a minor effect.
Rn. 92 · Rn. 116
This classification follows the European Commission's guidelines on Article 50 AI Act. The guidelines are not binding; only the Court of Justice of the EU can interpret the law bindingly. You make the decision.
The example
A store has AI double the size of older product photos of table lamps, remove noise and match the white balance to new photos. The brass and the colour of the shade stay as they are.
The answers in the labelling check
- Was an AI tool used to create or change this image?
Yes - Who used the AI tool?
Me or someone on my team - When was the image created or last changed with AI?
On 2 August 2026 or later - What did the AI do to this image?
Technical corrections only, such as colour, brightness, sharpness, dust, cropping, format or cut-outs. - Did the correction change the appearance of the product or person beyond normal photo editing?
No
Adapt these answers in the labelling check
When the result changes
- If the correction changes the product's appearance beyond normal photo editing, such as a different colour, extreme brightening or artificial gloss, a label is required. Under the guidelines, such extreme changes that alter the message are changes of content (para. 92).
- If the AI invents details such as seams, patterns or engravings while upscaling, or recolours the product, it has changed it (colour variant).
- If the AI only cuts the product out, see background removal.
What to do
- Compare the image with the goods, especially colour, surface and fine details, and record what the AI corrected.
- If you are not sure whether the colour is still right, choose “Not sure” in the labelling check. It then recommends the label.
Frequently asked questions
Doesn't AI upscaling always invent details?
An upscaler adds pixels. As long as only the resolution goes up and the product looks the same, re-scaling is editing with a minor impact under the guidelines (para. 116). Invented features on the product are a different matter.
Can I label voluntarily?
Yes, with accurate wording such as “edited with AI”, not “AI-generated”.
Sources
Para. refers to the paragraph number in the European Commission's guidelines on Article 50, C(2026) 5054.
- Commission Guidelines on the transparency obligations under Article 50 AI Act, C(2026) 5054 finalEuropäische Kommission · Commission · 20 Jul 2026
- Regulation (EU) 2024/1689 (AI Act)EUR-Lex · Law · 12 Jul 2024
AI-generated
