{"slug": "do-ai-generated-product-descriptions-need-a-label-under-article-50", "title": "Do AI-generated product descriptions need a label under Article 50?", "summary": "A guide drafted by an AI agent examines whether EU AI Act Article 50 requires online shops and agencies to label AI-generated product descriptions, concluding that it usually does not. The analysis finds that the 50(4) text duty covers only content published to inform the public on matters of public interest, not sales copy, while the 50(2) machine-readable marking duty falls on the providers of generation tools rather than the shops using them. It notes that realistic AI product images of real items may qualify as deep fakes requiring visible disclosure, and that the Digital Omnibus on AI (Regulation (EU) 2026/1744, Article 111(4)) extends the 50(2) marking deadline for pre-existing generative systems to 2 December 2026.", "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/ai-product-descriptions-article-50.html](https://mdodeja.github.io/eu-ai-act-article-50-guide/guides/ai-product-descriptions-article-50.html).*\n\n**Short answer.** Usually not. The Article 50(4) text duty covers text published to inform the public on matters of public interest, and an ordinary product description is not that. The machine-readable marking duty in 50(2) sits with the provider of the generation tool. The exception is images: a realistic AI product photo of a real item can meet the Act's definition of a deep fake, and that needs a visible disclosure.\n\nFor most online shops, writing product descriptions with an AI tool does not create an Article 50 labelling duty for the shop or for the agency writing the copy. Three paragraphs of Article 50 could be relevant, and each one usually misses product text for a different reason.\n\n| Paragraph | Who it binds | Does it reach a product description? | \n|---|---|---|\n| 50(1) | Providers of AI systems that interact directly with people | No. A description on a page is not an interaction. A shopping assistant that chats with customers is, and is covered separately. | \n| 50(2) | Providers of AI systems that generate synthetic text, images, audio or video | It binds the company that makes the generation tool, not the shop that uses it. | \n| 50(4), text | Deployers publishing AI text \"with the purpose of informing the public on matters of public interest\" | Generally no. Selling a kettle is not informing the public on a matter of public interest. | \n| 50(4), deep fakes | Deployers of AI that generates or manipulates image, audio or video content constituting a deep fake | Possibly, for realistic AI product images. See below. | \n\nThe second half of Article 50(4) is narrow. It covers AI-generated or manipulated text \"published with the purpose of informing the public on matters of public interest\". The Act does not define \"matters of public interest\", but the wording points at news, commentary and civic information, not at sales copy. Product titles, bullet points, category intros and size guides are written to sell, so they generally fall outside it.\n\nSome shop content sits closer to the line. A buying guide that reads like consumer journalism, a blog post on product safety recalls, or a page about a health or environmental claim could be read as public-interest text. If a piece could be taken either way, treat it as covered. Even then, the same paragraph exempts text that has gone through human review or editorial control where a person or company holds editorial responsibility for publishing it. The [guide on labelling AI-written articles](https://mdodeja.github.io/eu-ai-act-article-50-guide/guides/labeling-ai-written-articles.html) explains how to set that up.\n\nArticle 50(2) requires providers of AI systems that generate synthetic text, images, audio or video to mark the output in a machine-readable format so it can be detected as AI-generated. That is a duty on whoever develops the system and places it on the market under their own name, such as the company behind the writing tool or the image model.\n\nTwo practical points for agencies and shops:\n\nThe Digital Omnibus on AI (Regulation (EU) 2026/1744, Article 111(4)) gives generative systems already on the market before 2 August 2026 until 2 December 2026 to meet the 50(2) marking duty.\n\nThe first half of Article 50(4) applies to image, audio and video content, not text. Deployers of an AI system that generates or manipulates a deep fake have to disclose that the content is artificially generated or manipulated.\n\nArticle 3(60) defines a deep fake as AI-generated or manipulated image, audio or video content \"that resembles existing persons, objects, places, entities or events and would falsely appear to a person to be authentic or truthful\". The definition names objects, so it is not limited to faces. A photorealistic AI image that shows a real product, in a setting it was never photographed in or with features it does not have, can meet that definition if a shopper would take it for a real photo.\n\nHow that works out in practice:\n\nWhere the line between an edit and a manipulation falls is not spelled out in the Act. The Commission's guidelines on Article 50 address scope, so read them for borderline images.\n\nArticle 50(6) says the article is without prejudice to other transparency duties in EU and national law. For product pages, the bigger risk is usually consumer protection law: a description or image that misleads shoppers about the product is a problem whoever or whatever wrote it. AI tools invent specifications, materials and certifications, so a human should check every factual claim before it goes live. Marketplaces such as Amazon or Etsy may also have their own policies on AI images; check the platform's current rules.", "url": "https://wpnews.pro/news/do-ai-generated-product-descriptions-need-a-label-under-article-50", "canonical_source": "https://dev.to/mdodeja/do-ai-generated-product-descriptions-need-a-label-under-article-50-3of6", "published_at": "2026-10-21 00:14:41+00:00", "updated_at": "2026-10-21 00:19:37.196993+00:00", "lang": "en", "topics": ["ai-policy", "ai-ethics", "generative-ai"], "entities": ["European Union", "Digital Omnibus on AI", "Regulation (EU) 2026/1744"], "also_reported_by": [], "alternates": {"html": "https://wpnews.pro/news/do-ai-generated-product-descriptions-need-a-label-under-article-50", "markdown": "https://wpnews.pro/news/do-ai-generated-product-descriptions-need-a-label-under-article-50.md", "text": "https://wpnews.pro/news/do-ai-generated-product-descriptions-need-a-label-under-article-50.txt", "jsonld": "https://wpnews.pro/news/do-ai-generated-product-descriptions-need-a-label-under-article-50.jsonld"}}