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AI-LabelAI images, EU AI Act
Guide · ChannelsUpdated 11 October 20267 min read10 primary sources

EU AI Act labels in Google Merchant Center and Google Shopping

In your own store you label AI images under Article 50 of the EU AI Act with a visible label. In your product feed for Google, Google's own rules apply on top: metadata in the file, a setting for AI labels and rules on overlays.

In short

For AI labelling in the feed, Google Merchant Center requires product images created with generative AI to carry the IPTC DigitalSourceType entry with the value TrainedAlgorithmicMedia, for image_link, additional_image_link and lifestyle_image_link (help page 14743464). Embedded metadata must not be removed.

Your own AI labels in the image have been allowed since July 2026 and, according to Google, do not violate the rules on overlays and watermarks (help page 17231950). Keep them out of the very corners. Google does not take over your duty under Article 50 of the EU AI Act.

Key facts

What Google requires for AI images

Google handles AI images in Merchant Center through file metadata. According to help page 14743464, every image created with generative AI must carry metadata identifying it as AI-generated: the IPTC entry DigitalSourceType with the value TrainedAlgorithmicMedia. This applies to the feed attributes image_link, additional_image_link and lifestyle_image_link.

Google names two more values that should be preserved: CompositeSynthetic (a composite with synthetic elements) and AlgorithmicMedia (created purely by an algorithm). You must not remove embedded metadata. Google expressly includes images from its own tools such as Product Studio.

The right value for photos only partly changed with AI, for example with a new background, is not settled. Google Search supports compositeWithTrainedAlgorithmicMedia for this; Merchant Center does not mention it. If you want to be sure the feed recognises the entry, you can choose compositeSynthetic. The values are explained in C2PA, IPTC and metadata.

AI text: structured_title and structured_description

Google also has dedicated attributes for AI-generated product titles and descriptions. Instead of, or alongside, title and description, you use structured_title and structured_description. Each has two sub-attributes: digital_source_type set to trained_algorithmic_media, and content with the text. This is a Google requirement. Under the Article 50 guidelines, ordinary product descriptions fall outside the text labelling duty, except for claims on topics such as health, consumer safety or sustainability (para. 131).

Overlays and watermarks: an apparent contradiction

Merchant Center's general image specification (help page 6324350) still lists overlays and watermarks as reasons for disapproval, without an express exception for AI labels. The newer help page 17231950 says that your own AI labels in ads and listings do not violate the policies on text overlays and watermarks. The Google Ads policy change log of 9 July 2026 says the same: since July 2026, text or image labels in AI creatives are allowed.

Read them together: the newer, more specific page governs AI labels. Other overlays and watermarks remain a reason for disapproval under the image specification. So keep the label plain and clearly recognisable as an AI notice: the “AI” mark, optionally with a short text, and no marketing message.

The AI label setting in Merchant Center

Independently of any label in the image, you can mark an asset in Merchant Center as created or edited with AI. The setting is in the product details under “Manage images”: select the image, open the three-dot menu in the top right, choose “Manage AI label”, pick the option, apply and save. The same setting exists for Product Studio and video assets. Google describes the effect as follows:

Important: Google writes that the feature does not ensure compliance with certain regulations and advises seeking legal guidance. Under the guidelines, deployers may rely on the labelling tools of very large online platforms within those platforms (para. 126). How far that carries for Google's setting is unclear. We recommend both: Google's setting and a visible label in the image if the image is a deep fake.

Placement in the image: avoid the corners

Google warns that labels in the very corners and along the edges may be trimmed depending on the ad format, and that it cannot rule this out entirely. Our recommendation for a feed version with a burned-in label: keep at least 5 % of the image width from the edge, and make the mark about 8 % of the shorter image side tall. These are our own values; neither Google nor the Code gives sizes. How the label should look is covered in label design. You can create an image copy with a label in your browser with the label tool.

Shopify: does the metadata reach the feed?

Your product feed points to the image file your store delivers. On Shopify, that is an address on Shopify's CDN. A Shopify Community thread reported that this CDN stripped XMP metadata. Shopify staff wrote on 27 July and 4 September 2026 that the issue should be fixed. There is no official changelog entry. In our own test on 3 October 2026, one file kept its entry in the original, resized and as WebP. Check your own images: open an image address from your feed in the metadata checker.

Two common reasons for missing entries happen before Shopify: background removal and re-exports. Both write a new file, often without metadata.

Step by step: labelled in the store, clean in the feed, metadata intact

  1. Classify. For each AI image, establish whether it is a deep fake, for example with the labelling check. Record the result and citation.
  2. Use the original file with its metadata. Upload the file from the AI tool, not a screenshot or re-export.
  3. Add IPTC where it is missing. Add DigitalSourceType with the IPTC tool if the file has no C2PA manifest. Do not write to files with C2PA; the manifest would become invalid.
  4. Label visibly in the store. Add the label as an overlay on every surface where the image appears (see AI labels in online stores). An overlay does not change the file, so the feed receives the original with its metadata.
  5. Check the delivered file. Open the image address from your feed in the metadata checker and confirm the IPTC entry.
  6. Set the AI label setting. In Merchant Center, use “Manage AI label” to mark each AI image as created or edited.
  7. Decide whether the feed needs a burned-in label. For deep fakes we also recommend a feed version with a visible label, away from the corners. Copy the metadata into the new file.
  8. Check the preview. After the next fetch, check in Merchant Center that the label is fully visible and the image was not disapproved.
  9. Document. Record which feed images carry which version.

The label in your store only works in your store. For every channel of your own outside it, such as Google Shopping, Meta ads, newsletters or marketplaces, you take care of the label yourself. Overview: AI labels on platforms.

Frequently asked questions

Do I have to label AI images in Google Merchant Center?

Yes, through metadata: images created with generative AI must carry the IPTC DigitalSourceType entry with the value TrainedAlgorithmicMedia (help page 14743464). There is also the “Manage AI label” setting. Your visible labelling duty under Article 50 of the EU AI Act is separate.

Which IPTC value does Google require for AI images?

TrainedAlgorithmicMedia for images created with generative AI. CompositeSynthetic and AlgorithmicMedia should be preserved. Only Google Search, not Merchant Center, mentions compositeWithTrainedAlgorithmicMedia.

Can an AI label appear in a Google Shopping product image?

Yes. According to Google, your own AI labels in ads and listings do not violate the rules on text overlays and watermarks (help page 17231950, Ads policy change log of 9 July 2026). Keep the label out of the very corners.

Why does the image specification still say overlays are not allowed?

The general image specification (help page 6324350) has not been updated with an exception. The more specific page 17231950 deals with AI labels expressly. Other overlays and watermarks remain a reason for disapproval.

Does Shopify strip IPTC metadata from product images?

This was reported in the Shopify Community. Shopify staff wrote in July and September 2026 that it should be fixed. In our test on 3 October 2026 the entry survived. Check your image addresses with the metadata checker.

Is Google's AI label setting enough for Article 50?

That is unclear. Google itself writes that the feature does not ensure regulatory compliance. For deep fakes we also recommend a visible label in the image.

Sources

All sources read in full. Paragraph numbers (para.) refer to the European Commission's guidelines on Article 50, C(2026) 5054.

  1. Google Merchant Center: AI-generated contentGoogle · Platform · 3 Oct 2026
  2. Google Merchant Center: AI content label settings and disclosuresGoogle · Platform · 3 Oct 2026
  3. Google Merchant Center: image link requirementsGoogle · Platform · 3 Oct 2026
  4. Google Merchant Center: preserving image metadataGoogle · Platform · 1 Feb 2024
  5. Google Ads policy change log: labels in AI creativesGoogle · Platform · 9 Jul 2026
  6. Google Search Central: image metadata (IPTC, C2PA)Google · Platform · 10 Dec 2025
  7. Shopify Community: CDN stripping IPTC metadataShopify Community · Platform · 4 Sept 2026
  8. IPTC NewsCodes: Digital Source TypeIPTC · Standard · 23 Oct 2024
  9. Commission Guidelines on the transparency obligations under Article 50 AI Act, C(2026) 5054 finalEuropäische Kommission · Commission · 20 Jul 2026
  10. Regulation (EU) 2024/1689 (AI Act)EUR-Lex · Law · 12 Jul 2024

Not legal advice. This content explains the law based on primary sources; it does not replace an assessment of your individual case.

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