{"slug": "ai-shopping-assistants-on-product-pages-disclosure-recommendations-and-returns", "title": "AI shopping assistants on product pages: disclosure, recommendations and returns questions", "summary": "A developer-published guide outlines how e-commerce sites should deploy AI shopping assistants under EU rules, arguing that Article 50 of the AI Act requires disclosure that a chatbot is AI at the latest in its first message, not buried in the shop's terms. The guide also advises that product and sizing answers be grounded in product data to comply with the Unfair Commercial Practices Directive, that marketplace assistants explain ranking and label paid placement, and that returns answers match the Consumer Rights Directive's 14-day withdrawal right, citing Moffatt v. Air Canada as a cautionary case.", "body_md": "*This guide was drafted by an AI agent from the primary sources linked at the bottom, and has not been reviewed by a lawyer. It is general information, not legal advice. The original is at [https://mdodeja.github.io/eu-ai-act-article-50-guide/guides/ecommerce-product-page-ai-chat.html](https://mdodeja.github.io/eu-ai-act-article-50-guide/guides/ecommerce-product-page-ai-chat.html).*\n\n**Short answer.** A shopping assistant needs the Article 50 disclosure before the customer types, like any chatbot. Its product and sizing answers are the shop's statements, so they should come from the product data. On a marketplace, an assistant that ranks products from different sellers in answer to a query is covered by the consumer-law rules on ranking transparency and paid placement; on a single-brand shop those specific rules don't apply, but hidden commercial reasons for a recommendation can still mislead. Returns answers must match the Consumer Rights Directive: in most cases 14 days to withdraw from an online purchase of goods.\n\n| Part of the chat | Rule | What to do | \n|---|---|---|\n| Assistant greets the customer | AI Act Article 50(1) and (5) | Say it is an AI, at the latest at the first message | \n| Product facts, sizing, materials | Unfair Commercial Practices Directive, Articles 6 and 7 | Answer from the product data, say when it is unknown | \n| \"Show me the best running shoes\" on a marketplace | UCPD Article 7(4a) and Annex I point 11a | Explain how results are ranked; label paid placement | \n| Returns and refunds | Consumer Rights Directive, Articles 6(1)(h) and 9 | State the withdrawal right correctly | \n\nArticle 50(1) applies to an AI system that interacts directly with people, and Article 50(5) says the information has to come at the latest at the first interaction. On a product page, that means in the assistant's first message or the chat panel header, not in the shop's terms:\n\n\"Hi, I'm the shop's AI assistant. Ask me about sizing, materials or delivery. For an order problem I can put you through to our team.\"\n\nA sparkle icon and the word \"Assistant\" are not obviously an AI to every customer. Say it in words. More options are in the [disclosure wording guide](https://mdodeja.github.io/eu-ai-act-article-50-guide/guides/chatbot-ai-disclosure-wording.html).\n\nWhat the assistant says about a product is the shop speaking. Under the Unfair Commercial Practices Directive, false information about a product's main characteristics, and leaving out information the customer needs, are misleading practices.\n\nSince the 2019 amendments to the Unfair Commercial Practices Directive (Directive (EU) 2019/2161), two rules apply when a consumer can search for products \"offered by different traders or by consumers\":\n\nA marketplace assistant that answers \"which blender should I buy?\" with products from several sellers is providing results to a query, so both rules are worth applying to it: a short line on how it chooses (\"I rank by your filters, rating and price; sponsored items are labelled\") and a visible \"Sponsored\" label on paid items.\n\nOn a single-brand shop selling only its own products, these two provisions don't apply as written, since all products come from one trader. The general rule still does: a recommendation driven by a commercial reason the customer can't see (a supplier bonus, clearing old stock) and presented as neutral advice can be misleading. Keep the assistant's reasons honest (\"This one is on sale this week\").\n\nCustomers ask the assistant about returns more than anything else. The answers have to match the law and the shop's own policy.\n\nA wrong answer here is costly: the pre-contract information on withdrawal is part of the contract (Article 6(5)), and a Canadian tribunal held Air Canada to a refund policy its chatbot described wrongly (Moffatt v. Air Canada, 2024 BCCRT 149, reported; not EU law).", "url": "https://wpnews.pro/news/ai-shopping-assistants-on-product-pages-disclosure-recommendations-and-returns", "canonical_source": "https://dev.to/mdodeja/ai-shopping-assistants-on-product-pages-disclosure-recommendations-and-returns-questions-38dn", "published_at": "2026-11-07 00:13:46+00:00", "updated_at": "2026-11-07 00:22:42.113995+00:00", "lang": "en", "topics": ["ai-policy", "ai-agents", "ai-products"], "entities": ["Air Canada", "European Union", "Moffatt v. 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