Amazon AI-Generated People: What Sellers Need to Know About the New Disclosure Requirements
AI-generated product imagery has quickly become a normal part of e-commerce. Brands can now create product scenes, lifestyle photography, and even realistic human models without scheduling a photo shoot.
But there is a new consideration for Amazon sellers: what happens when the person in your product image was generated by AI?
Amazon has introduced guidance requiring sellers to identify applicable media containing AI-generated people using specific XMP metadata. At the same time, New York has enacted a new law requiring certain commercial advertisements containing synthetic performers to include a conspicuous disclosure.
For brands using AI-generated people in Amazon listings, this creates a practical reason to review existing image libraries and establish a process for properly identifying and disclosing synthetic people.
Amazon's contains-synthetic-performer requirement
Amazon's current seller guidance addresses media that contains an AI-generated person.
According to Amazon, if an image or video contains an AI-generated human, sellers must add the keyword:
contains-synthetic-performer
to the image's XMP dc:subject metadata field before uploading it to Amazon. Amazon specifically describes this as a way to tag applicable media in jurisdictions where disclosure of AI-generated people is required.
Amazon's A+ Content guidelines provide additional clarification. For A+ content, Amazon says that images containing photorealistic AI-generated people must be tagged with the appropriate metadata before being uploaded. Amazon also provides an option inside Creative Assets for identifying AI-generated people, allowing Amazon to apply the necessary metadata in that workflow.
This is important because simply knowing that an image was created with AI isn't necessarily the same thing as properly tagging the file.
The metadata needs to be in the specific XMP field Amazon identifies.
What does contains-synthetic-performer actually mean?
The phrase can sound more complicated than it is.
In practical terms, Amazon is looking for metadata that identifies an image as containing an AI-generated person.
The required keyword is:
contains-synthetic-performer
Amazon specifies that the value belongs in the image's XMP dc:subject field. Its documentation provides instructions for adding the tag using tools available on macOS and Windows, as well as command-line tools such as ExifTool.
The distinction is important because metadata can exist in several different places inside an image file. Amazon specifically says to use the XMP dc:subject field.
Why New York's new law matters
Amazon's policy is not the only reason companies should pay attention to AI-generated people in advertising.
New York amended General Business Law §396-b through legislation signed by Governor Kathy Hochul on December 11, 2025. The law became effective June 9, 2026.
The law defines a "synthetic performer" as a digitally created asset made, reproduced, or modified by a computer using generative AI or a software algorithm that is intended to create the impression that the asset is performing as a human performer who is not recognizable as an identifiable natural performer.
For covered commercial advertisements, the law requires a conspicuous disclosure that a synthetic performer appears in the advertisement when the person responsible has actual knowledge of it.
The statute establishes civil penalties of $1,000 for a first violation and $5,000 for subsequent violations.
There are also exceptions and limitations in the law, including certain expressive works and other circumstances, so businesses should not assume that every image created with AI automatically falls under the statute.
In other words, this is not simply an "AI was used" law.
The specific question is whether the advertisement contains a synthetic performer as defined by the statute.
This is bigger than Amazon
The practical issue for brands is that product imagery rarely lives in only one place.
A single product image may appear on:
Amazon product listings
Amazon A+ Content
Your own website
Shopify
Paid advertising
Social media
Email campaigns
Retailer websites
Catalogs
Digital marketplaces
Sales presentations
If a company has adopted AI-generated people as part of its creative workflow, it should know where those images are being used and what disclosure or metadata requirements apply to each channel.
That means the solution isn't simply changing one Amazon image.
It is creating a repeatable workflow for identifying AI-generated people and preparing the associated files correctly.
What Amazon sellers should do now
If your company uses AI-generated people in product photography or lifestyle imagery, start by auditing your existing assets.
1. Identify images containing AI-generated people
Create a list of product images, lifestyle images, A+ modules, and other marketplace assets that contain synthetic or entirely AI-generated people.
Don't assume that an image is exempt simply because it started as a photograph and was later edited. Review the actual creative process and determine whether the resulting person falls within the applicable requirements.
2. Separate your image types
Not every Amazon image serves the same purpose.
For example, Amazon's guidance discusses AI-generated people in A+ content, while Amazon's general product-image rules can place additional restrictions on main images.
Your workflow should therefore distinguish between:
Main product images
Secondary listing images
A+ Content
Other promotional imagery
This makes it easier for your creative team to apply the appropriate treatment to each asset.
3. Add the required metadata
For applicable Amazon media, Amazon specifies the keyword:
contains-synthetic-performer
in the XMP dc:subject field.
The important part is making sure the tag actually exists in the file—not simply putting the phrase in a filename or somewhere in the visible image.
4. Verify the file before uploading
Metadata can be surprisingly easy to lose during image processing.
A file may be resized, exported, compressed, converted, or passed through another application before it reaches Amazon.
That's why verification should be part of the workflow.
Amazon itself recommends verifying that the contains-synthetic-performer value is present in the XMP dc:subject field.
5. Keep your original files
Don't overwrite your original creative assets when adding metadata or creating disclosure versions.
Maintain a clean source file and create appropriately tagged production files for marketplace use.
This becomes especially important when multiple versions of the same product imagery are being used across Amazon, your website, paid advertising, and other retail channels.
The problem: doing this manually doesn't scale
For a company with five product images, manually editing metadata isn't particularly difficult.
For a company with hundreds or thousands of marketplace images, it becomes a production problem.
Someone has to:
Find the applicable images.
Identify images containing AI-generated people.
Add the correct metadata.
Decide whether a visible disclaimer is appropriate.
Export the image.
Verify the metadata.
Upload the new asset.
Keep track of what has been processed.
That's a lot of repetitive work for a creative or marketplace team.
And if your company is already using AI-generated people throughout its product imagery, waiting until every marketplace team figures this out independently can create unnecessary confusion.
A faster way to prepare your Amazon images
That's why we built the Amazon AI Human Disclaimer Tool + Metadata Tagger.
The free browser-based tool lets you add a visible AI-human disclaimer, embed the contains-synthetic-performer XMP metadata tag, or use both depending on the image.
You can process multiple JPG and PNG files, customize the disclaimer, preview its placement, export the processed images, and verify whether the metadata tag is actually present in the resulting file.
Most importantly, your images never leave your browser. The tool processes the files locally rather than uploading them to a server.
[Use the Free Amazon AI Human Disclaimer Tool →]
If your company has already started using AI-generated people in Amazon imagery, this is a good time to establish a repeatable process rather than handling each image manually.
What this tool does—and what it doesn't
The tool is designed to make the technical part of the workflow faster.
It can:
Add contains-synthetic-performer to XMP metadata
Add a visible AI-generated-person disclaimer
Process multiple JPG and PNG images
Provide a mobile preview
Verify the resulting XMP metadata
Download individual processed images
Download processed images as a ZIP
Process images locally in the browser
The tool does not determine whether your particular image is legally required to contain a disclosure, and using the tool does not guarantee compliance with every Amazon policy or applicable law.
Amazon's policies and applicable laws can change, and businesses should review the current requirements that apply to their products, advertising, and jurisdictions. The tool itself also displays this limitation to users.
AI-generated people are becoming part of the e-commerce workflow
The larger takeaway isn't that brands should stop using AI-generated people.
It's that brands need to understand where AI-generated humans are being used and build disclosure and metadata into the production process.
For a creative team, that can be as simple as adding one more step to the image-production checklist:
AI-generated person? → Identify → Tag → Verify → Upload
Doing that consistently is much easier than trying to reconstruct the history of hundreds of images after the fact.
As marketplaces and governments continue developing rules around synthetic media, having a documented process for your product imagery can save your team time and reduce the chance of missing an important requirement.
Start tagging your Amazon images
If you're already using AI-generated people in your Amazon listings, you don't have to manually edit every file one at a time.
Use the free Amazon AI Human Disclaimer Tool + Metadata Tagger to process and verify your images faster.
This article is provided for informational purposes and is not legal advice. Amazon policies and applicable laws can change. Review Amazon's current seller guidance and consult qualified legal counsel for questions about your specific advertising, products, or jurisdictions.
