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Actors

Deployer

Uses an AI system professionally — your store when you publish AI product photos.

Art. 3(4)Art. 26

Definition

A deployer is any natural or legal person using an AI system under its own authority in the course of a professional activity. Deployer means any person using an AI system under their own authority in a professional context. In practice: when your Shopify store publishes AI-generated or AI-altered product photos, you are the deployer — not Midjourney or your design agency. Article 50 requires visible disclosure at first exposure on the product page.

What this means for your store

The deployer duty follows publication, not creation. Whoever pushes the image live in the storefront is the one who has to disclose it.

Related terms

Related obligations

This page is a plain-language summary for orientation only. It is not legal advice — the binding text is Regulation (EU) 2024/1689.

Label your AI product photos before August 2026

EU AI Label adds CoP-aligned EU AI icons to AI-generated and AI-modified product photos on Shopify and WordPress, and keeps the metadata log your Compliance Hub needs.

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