EU AI Act 2026: how to be compliant as a merchant
If you run a Shopify or WooCommerce store and use AI for any of your product photography, here's the short version: from 2 August 2026, shoppers need to see a clear, visible label the first time they view a product photo that was AI-generated or materially AI-altered. This guide walks through exactly what that means for your store, step by step.
Not legal advice. This guide supports transparency workflows for deployers under Regulation (EU) 2024/1689 Article 50. Confirm obligations with counsel for your store's specific facts.
You are the "deployer" — here's what that means
Article 50 splits responsibility by role:
| Role | Who | Duty |
|---|---|---|
| Provider | The AI tool that generated the image (Midjourney, ChatGPT, Adobe Firefly, etc.) | Machine-readable marking at creation (Art. 50(2)) |
| Deployer | You — the merchant publishing the image on your store | Clear, accessible label at first exposure (Art. 50(4)/(5)) |
| Shopper | Your customer | Must see the disclosure without hovering, clicking, or scrolling |
If an agency built or runs your store, you're still typically the deployer — they can help you implement labeling, but the disclosure duty sits with the business publishing the content. If you work with an agency, point them to our agency guide so everyone's aligned on who does what.
Want the plain-English version of the whole law first? Read it here →
Do I need to label my product photos?
Usually yes, if:
- The product photo was created substantially with AI, or
- A real photo was materially changed with AI — background swap, a synthetic model added, objects added or removed, and
- A shopper could reasonably think the image is a real photo of the product or scene.
Usually lower priority if:
- It's a decorative blog illustration that's clearly stylized
- It's an abstract graphic or icon
- It's minor retouching or color correction only
Rule of thumb: if the image could be read as "this is what it really looked like," plan to label it.
Selling into the EU from outside the EU? Often still relevant in practice — confirm your exposure with counsel.
What to label first (priority order)
You don't need to label your entire catalog overnight. Work down this list:
High — start here
- AI studio shots, synthetic models, AI-generated backgrounds
- Ads and landing pages with realistic synthetic people or results
- Fashion/beauty before-after or model imagery
- Fake venue, travel, or destination photos
Medium
- "Our work" or case study pages with synthetic photography
- Synthetic team or office photos
Low — usually later
- Decorative blog AI art
- Stylized illustrations and abstract visuals
AI-generated vs AI-altered: use two clear categories
Keeping just two internal categories makes this easy to manage across a catalog:
| AI-generated image | AI-altered photo | |
|---|---|---|
| Meaning | Substantially created by AI | Real photo, materially changed with AI |
| Examples | Full synthetic scene, prompt-generated product render | Background swap, object add/remove, AI model on a real product |
| Recommended label text | "AI-generated image" | "AI-altered photo" |
| EU icon preset | AI + GENERATED | AI + MODIFIED |
| Usually skip | — | Minor retouch, color correction only |
Avoid vague label wording like "enhanced" or "virtual" — the Code of Practice's own user-testing found that clear text-first labels outperform icon-only badges, and vague words don't count as clear disclosure.
Where the label needs to appear
- Visible at first exposure — no hover, click, or scroll required to see it.
- Text-first, not icon-only (icons can accompany the text, not replace it).
- On or immediately next to the product photo — not in a footer or a separate compliance page only.
- Readable contrast on both light and dark product photos, and legible on mobile.
A separate "AI transparency" page on your site is a good governance layer — it's just not a substitute for the label on the image itself.
Your 6-step checklist
- Audit — List product photos (and key page images) that used AI.
- Classify — AI-generated, AI-altered, or no label needed.
- Choose your tool — see the table below.
- Configure — label text, position, and language for your markets; preview before publishing.
- Turn on evidence — enable a Compliance Hub page or site-wide manifest.
- Keep it updated — label new AI photos as you publish new campaigns.
Which tool do I use?
| Your situation | Tool | Link |
|---|---|---|
| Shopify or WordPress product photos, at scale | EU AI Label | euailabel.app |
| One image for social, a marketplace listing, or a deck | EU AI Icon | euaiicon.com |
| Labels across your entire website (any platform) | AI Act Icon | aiacticon.com (~mid August 2026) |
| Comparing all three at once | Full toolkit | aiact.solutions |
EU AI Label (Shopify · WordPress · WooCommerce)
Visible overlays on product photos via a theme app extension — no theme code edits. Includes bulk tagging, a Compliance Hub page, an audit log, and multi-language badges for EU storefronts.
- Free: up to 10 labeled product photos
- Starter: €7/mo — up to 100 labeled photos, AI-generated/AI-altered presets, EU icon templates
- Growth: €15/mo — up to 500 labeled photos, custom label text, styling controls
See live pricing at euailabel.app/pricing.
EU AI Icon (any file, any channel)
A free browser tool that burns a visible AI-generated/AI-modified badge directly into an image's pixels — ideal when a file leaves your store (social post, marketplace listing, PDF, email). 10 free downloads/day, no account needed.
AI Act Icon (any website)
Scans your site, classifies AI images, and deploys one badge script — useful if you have pages beyond your product catalog that need coverage without touching every template. Free tier covers 1 site and 500 images.
What we help with — and what we don't
We help with:
- Visible, text-first labels at first exposure
- Labeling product photos without rewriting your Shopify image files
- A simple audit trail via your Compliance Hub
- Site-wide disclosure workflows (AI Act Icon)
- Off-site burned-in labels for files that leave your store (EU AI Icon)
We don't:
- Guarantee legal compliance — that's a decision for your counsel
- Replace provider metadata or C2PA marking
- Handle chatbot "you are talking to AI" notices (Art. 50(1) — usually your chat vendor's job)
- Label product descriptions or AI-written blog text
- Preserve metadata through Shopify's CDN (it's often stripped regardless of tool)
Availability
| Product | When |
|---|---|
| EU AI Label — WordPress | Live now (free tier) |
| EU AI Label — Shopify | Private install from 30 July 2026 · App Store ~mid August 2026 |
| AI Act Icon | Public launch ~mid August 2026 |
| Article 50 applies | 2 August 2026 |
Working with an agency? Many partners already have private install access — see our agency guide to send them.
FAQ
Does every product photo need an AI label?
No. Focus on photos that are AI-generated or materially AI-altered and could pass as real. Minor retouching and color correction are usually lower priority. See the full deployer FAQ for borderline cases.
Does provider metadata (like a Midjourney watermark) make me compliant?
No. That's mainly a provider-side signal, and platforms like Shopify's CDN often strip it on upload anyway. Deployers need a visible label that shoppers actually see.
Can I use just an icon instead of text?
No — not as the primary disclosure. Text-first labels (optionally paired with an icon) perform significantly better in EU Code of Practice user testing than icon-only badges.
Do I need this if my store isn't based in the EU?
Often yes in practice if you sell to EU customers. Confirm your specific exposure with counsel.
Where do I start if I only have a few AI product photos?
Start with EU AI Label's free tier (up to 10 labeled photos) or the Shopify AI Act checklist for a step-by-step walkthrough.
Get started
Compare the full toolkit at aiact.solutions, label Shopify/WordPress product photos with EU AI Label, burn a one-off label at EU AI Icon, or cover an entire site with AI Act Icon.
EU AI Label, EU AI Icon, and AI Act Icon support transparency workflows under Regulation (EU) 2024/1689 Article 50. They are not legal advice and do not guarantee compliance. Confirm obligations with counsel for your specific case.