Must “AI rendering of a product that does not exist yet” be labeled under Art. 50?
Web & Shop — Without an existing object the deepfake definition barely applies. Instead you risk misleading advertising if the image suggests a shippable product.
Special case
No classic AI Act duty, but other risks apply. Without an existing object the deepfake definition barely applies. Instead you risk misleading advertising if the image suggests a shippable product.
How to implement
- •Mark it as a concept illustration or prototype whose production version may differ. Re-check at launch: the object then exists.
- •Place the label directly on the image or video. Not in terms or at the end of the description.
- •Videos: notice at the start and repeat regularly.
Orientation based on the EU AI Act (Art. 50). Not legal advice. For borderline cases consult a qualified lawyer. Effective from 02.08.2026 · ai-act-checker.com
Related scenarios
- AI lifestyle hero image (mockup)Deceptively real depiction. Labeling required.
- Cut-out + color correctionClassic editing without AI. No labeling needed.
- Usage example (model + AI background)Realistic usage scene can be misunderstood as real.
- Dimension sketch / icon set / schematicObviously graphic. No deceptive realism.