Know the difference between "edited" and "deepfake"
The law's disclosure trigger is a legal concept called a deepfake: content realistic enough that someone could mistake it for an authentic, unedited photo of a real person, place, or thing.
Low risk, no label needed:
- Removing or replacing a background
- Cropping, color correction, minor retouching
- Removing a small defect or blemish for cleanup purposes
- Clearly stylized or illustrative graphics that nobody would mistake for a real photo
Higher risk, label your listing:
- Fully AI-generated "lifestyle" shots that place your product in a photorealistic scene designed to look like a genuine photograph
- Removing or altering a real, identifiable object, person, or element in a way that changes what the image appears to show
The rule of thumb: if a shopper could reasonably mistake it for an unedited photo, add a simple visible note, something as light as "AI-generated image" near the product photo. If it's obviously a rendered or stylized graphic, you're already in the clear.
This one's easy
Titles, descriptions, bullet specs, category copy: none of this needs a label. The law's text-disclosure rule only covers content published to inform the public on matters of public interest (politics, public health, safety, and similar topics). Ordinary commercial product content sits outside that entirely.
On top of that, if a person reviews AI-generated text before it goes live, which most enrichment workflows already do, that content is exempt from the labeling duty even in edge cases.
Bottom line: no changes needed to how you publish product copy.
