Guides · Article 50 · EU AI Act
What manufacturers should know about Article 50
Manufacturers meet Article 50 of the EU AI Act mostly at the customer-facing edge: support and product-help chatbots, and AI-generated marketing content such as product imagery and copy. Two paragraphs tend to be relevant — 50(1) on AI-interaction disclosure and 50(2) on marking synthetic content. This guide gives a general overview for manufacturing teams. It is informational only, not legal advice, and does not determine whether the Act applies to your systems.
Support and product-help chatbots — Article 50(1), providers
Article 50(1) provides that providers must ensure AI systems intended to interact directly with natural persons are designed so those people are informed they are interacting with an AI system, unless that is obvious to a reasonably well-informed, observant and circumspect person given the context (Regulation (EU) 2024/1689). A product-help bot or a warranty-support assistant interacts directly with people, so this provider-side duty is in view. Article 50(5) points toward a clear notice at the latest at first interaction, meeting applicable accessibility requirements.
AI-generated product marketing — Article 50(2), providers
Marketing teams that generate synthetic images, video, or copy — a rendered product hero shot, AI-written descriptions — may bring Article 50(2) into view for the provider of the generating system: it points toward marking outputs in a machine-readable format as artificially generated or manipulated, with solutions effective, interoperable, robust and reliable as far as technically feasible, subject to carve-outs including assistive standard editing and no substantial alteration. Whether a given output falls inside the paragraph, and who is provider versus deployer, are fact-specific.
Article 50 is not the whole Act for manufacturing
Article 50 covers only the transparency obligations; depending on your systems, other parts of the EU AI Act — including high-risk-system requirements — may also apply. Confirm your full obligations with qualified counsel. AI embedded in products as safety components is a natural area for provisions well beyond Article 50, which are outside this guide.
Common questions
Does AI-generated product imagery need to be marked?
Article 50(2) points the provider of the generating system toward machine-readable marking of synthetic outputs, subject to carve-outs. Whether it applies to a given output, and whether you are the provider, are fact-specific — confirm with qualified counsel. Our free scope check gives an informational read on which paragraphs may be in play.
See what may apply to your business
Answer seven quick questions for an automated, informational indication of which Article 50 obligations appear likely to apply — free, and not legal advice.