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.

Sources and a step-by-step process are in the Google Merchant Center guide.

How this relates to your Article 50 duty

Deep fakes that you generate or manipulate with AI in your business, or have a contractor create to your instructions, must be disclosed (Article 50(4) AI Act, guidelines paras. 12 and 14). This applies in your own store and on every platform.

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

The Commission lists Google Shopping as a very large online platform. There, deployers may rely on the platform's labelling tools under para. 126 of the guidelines if they allow a clear and distinguishable disclosure. How far this carries is not settled, especially for notices that appear only sometimes or only after a click.

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. The current wording of the platform rules is what counts. A label does not make a misleading image lawful.