Labelling AI images in Google Shopping

What Google Shopping requires

• IPTC in the file: images created with generative AI carry DigitalSourceType = TrainedAlgorithmicMedia, for image_link, additional_image_link and lifestyle_image_link.
• Keep metadata: embedded data must not be removed.
• AI labels in the image: allowed, but not in the outermost corners and edges, because Google crops depending on the format. The general image specification (help article 6324350) still lists overlays as a reason for rejection; the newer article 17231950 governs AI labels.
• “Manage AI label” setting: assets can be marked in Merchant Center as created or edited with AI. Google states that the feature does not ensure that regulations are met.

Details, sources and a step-by-step process are in the Google Merchant Center guide.

How this relates to your Article 50 duty

Anyone who uses an AI system professionally to generate or manipulate image, video or audio content that is a deep fake must disclose it (Article 50(4) AI Act). A retailer is that deployer when it, or a contractor working to its instructions, uses AI for product or advertising images (guidelines, paras. 12 and 14). The duty follows the image, not the platform: it applies in your own store just as on a marketplace. Whether an image is affected is answered by the labelling check.

The IPTC field is machine-readable. Article 50(5) requires a disclosure people perceive. According to Google, labelled assets in campaigns targeting the EU receive a visible overlay; Google does not promise the display, though. We recommend both: the Google setting and your own label in the image.

Google Shopping is on the Commission's list of very large online platforms. Under the guidelines, deployers may rely on such a platform's labelling tools within that platform if the tools allow a clear and distinguishable disclosure, and only in the context of that platform (para. 126). How far this carries for a given tool is not settled. A platform label that appears only sometimes, or only after a click, does not automatically replace your own visible disclosure.

Steps

1. Check every AI image with the labelling check.
2. Write the IPTC field into the file, for example with Write AI metadata, and check that it reaches the delivered image.
3. Use the “Manage AI label” setting in Merchant Center.
4. If the image needs a visible label, use a feed version with the label burned in and a margin from the edge, made with Label an AI image.

Not legal advice. Platform rules change; the platform's current wording is what counts. A label does not make a misleading image lawful.

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