Amazon now wants a hidden metadata tag on every photorealistic AI face in your product images

Why put the disclosure in metadata rather than on the image?

Because metadata travels with the file. It survives copying, re-uploading and passing between systems, whereas a watermark can be cropped and a caption rewritten, and it stays machine-readable for the kind of audit a regulator or a platform would actually run. It is not a substitute for telling the shopper, though — Amazon says that where the tag is present it adds its own indicator on the listing. Sellers supply the metadata; Amazon decides what the customer sees. The trade-off is that a seller cannot tell from the page whether a given file was ever tagged.

Does this apply outside New York?

Yes. New York's law is the trigger, but Amazon applied the requirement across its stores worldwide rather than trying to enforce it state by state. If your listing shows an AI-generated person, the tag is expected regardless of where you sell.

Who is liable, the seller or Amazon?

The business that creates the advertisement. New York's law puts the disclosure duty on the advertiser, not on platforms that merely distribute the ad, which is exactly why Amazon is pushing the requirement down to sellers. Penalties run $1,000 for a first violation and $5,000 for each one after.

What counts as a "synthetic performer"?

A photorealistic human figure generated entirely by AI. New York's statute defines a synthetic performer as a digitally created asset made or modified by generative AI that is meant to read as a human performance by someone not recognisable as any identifiable real person. Amazon's version excludes real people whose appearance was AI-altered, characters from films, television, streaming, documentaries or games, images with no people, and figures that are not photorealistic. Background removal without a synthetic human is not the target.

What happens if a seller does not tag?

Amazon's notice does not say. It sets out no grace period, no detection method and no penalty specific to the tag. What exists is the general image policy, which already lets Amazon pull non-compliant media or suppress a listing — so the exposure is real but undefined. For large catalogs the harder problem is upstream anyway — finding every affected asset, not tagging it.