According to Seller Central, images with photorealistic, fully AI-generated people get the keyword contains-synthetic-performer in the XMP field dc:subject. Amazon may then add a notice.
Whether an AI image needs a visible label under Article 50 of the AI Act is something you check for every image, including images without people.
What Amazon requires
According to Seller Central (help pages G1881 and GFXHCHYZRGJRBZA5, US and Germany):
- Images with photorealistic, fully AI-generated people get the keyword
contains-synthetic-performerin the XMP fielddc:subject. - Do not tag real people who were only modified with AI, characters from works, images without people, or people not shown photorealistically.
According to a secondary source, the background is the New York State law on synthetic performers in advertising (General Business Law § 396-b), in force since 9 June 2026.
How this relates to your Article 50 duty
Deep fakes that you generate or manipulate with AI in your business, or have a contractor create to your instructions, must be disclosed (Article 50(4) AI Act, guidelines paras. 12 and 14). This applies in your own store and on every platform.
Article 50(5) requires a disclosure that people notice at their first view of the image. A keyword in the file does not do that. An AI product image without people can be a deep fake too.
The Commission lists Amazon as a very large online platform. There, deployers may rely on the platform's labelling tools under para. 126 of the guidelines if they allow a clear and distinguishable disclosure. How far this carries is not settled, especially for notices that appear only sometimes or only after a click.
Steps
- Check every AI image with the labelling check.
- For photorealistic, fully AI-generated people, add
contains-synthetic-performertodc:subject. Check an AI image shows whether it is in the file. - Do not remove existing AI metadata such as IPTC or C2PA.
- If the image needs a visible label, check the image requirements (G1881) first, especially for the main image. Label an AI image creates a copy with the label burned in.
- Record your decision and the reason.
Not legal advice. The current wording of the platform rules is what counts. A label does not make a misleading image lawful.
Frequently asked questions
Do I have to tag every AI image on Amazon?
No, only images with photorealistic, fully AI-generated people. The check under Article 50 of the AI Act still applies to every AI image.
Is the keyword enough for the EU AI Act?
The keyword itself cannot be perceived. Whether a notice Amazon then adds is enough in a given case (guidelines, para. 126) is not settled.
May I put an AI label into the product image?
Check Amazon's image requirements (G1881) first, above all for the main image. In your own store you can show the label as an overlay on the image.
Sources
Para. refers to the paragraph number in the European Commission's guidelines on Article 50, C(2026) 5054.
- Amazon Seller Central: tagging AI-generated people in imagesAmazon · Platform · 3 Oct 2026
- Amazon Seller Central: product image requirements (G1881)Amazon · Platform · 3 Oct 2026
- New York General Business Law § 396-b (synthetic performers)New York State Senate · Law · 9 Jun 2026
- European Commission: list of designated very large online platforms and search enginesEuropäische Kommission · Commission · 7 Sept 2026
- 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
