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This article breaks down New York State’s new regulation on AI-generated synthetic performers in advertising, along with the current situation facing Amazon sellers and their available response options.

1. Core requirements of the new rule: Any advertisement that uses AI-generated hyper-realistic models faces fines if it fails to make the required clear disclosure. First-time violations carry a $1,000 fine, while repeat violations can cost up to $5,000. The regulation also clarifies its scope: it only applies to AI-generated human-related content, and does not cover routine AI optimization tasks such as AI photo retouching, background replacement or scene generation.

2. Available courses of action for stakeholders: Amazon has not yet issued a unified compliance mandate, and has only opened an AI content labeling entry for A+ Content, with no such entry available for main and sub product images. Industry players can either wait for platform guidance before adjusting their content, or proactively label eligible A+ Content in advance to mitigate compliance risks.

This new regulation clarifies compliance requirements for AI marketing materials and outlines related risks and response strategies for cross-border brands operating in the New York State market.

1. Compliance responsibility definition: As the entity legally responsible for advertising content, brands must audit all AI-synthetic人物content in advertisements running in New York State. Clear disclosure is required for all AI-generated content including faces, full-body models, people holding products, customer review photos featuring people and people in talking-head videos. Non-disclosure can result in fines of up to $5,000. Routine AI operations such as retouching and background replacement are not subject to the regulation.

2. Risk and response guidance: Categories such as fashion that heavily rely on AI models will face greater impact, as labeling AI-generated models may trigger consumer pushback and hurt sales. Currently, Amazon only offers a labeling entry for A+ Content. Brands can choose to either proactively audit and label compliant materials in advance, or wait for the platform to release unified rules and observe actions taken by top sellers before adjusting their content.

New York State’s new regulation requiring disclosure of AI-synthetic models has officially gone into effect, and it has a notable impact on Amazon US sellers. This article summarizes policy interpretation, risk analysis and response solutions below.

1. Policy and responsibility interpretation: The regulation only governs AI-generated hyper-realistic human content, excluding routine operations such as AI retouching, background replacement and scene generation. Sellers and brands are the primary responsible parties, while Amazon as a platform bears no liability. Violations can result in fines of up to $5,000.

2. Current status and solutions: Amazon has not yet released a clear unified compliance requirement, and has only opened an AI content labeling entry for A+ Content, with no entry available for main and sub images. Sellers can either wait for platform notification before making adjustments to avoid unnecessary work, or proactively label eligible content in advance to mitigate compliance risk. Fashion sellers should note that labeling may hurt conversion rates.

New York State’s new AI advertising regulation provides valuable insights for digital marketing and clarifies future compliance directions for factories doing export manufacturing or selling their own branded products overseas.

1. Compliance trend insights: More and more regions overseas are rolling out formal regulations for AI-generated marketing materials. If a factory operates its own brand and manages its own platform storefronts, it should audit the compliance of its marketing materials in advance. In particular, factories that use AI models for product displays need to prepare for disclosure in accordance with local regulations ahead of time to avoid fines for violations.

2. Business adjustment directions: Many factories currently use AI-generated materials to cut photography costs. The new regulation makes clear that AI-driven cost reduction must go hand in hand with compliance. Factories can establish an internal material compliance review process in advance, or partner with compliant material service providers to meet requirements. Since labeling AI content may hurt consumer conversion, factories with their own brands can prioritize building a library of real-life model photos to balance costs, compliance and conversion performance.

Following the entry into force of New York State’s new AI advertising regulation, cross-border marketing service providers are facing new industry changes and can tap into new business opportunities. Key takeaways are summarized below.

1. Industry development trends: Regulation of AI marketing materials has officially gone into effect overseas, and more countries and regions are likely to introduce similar rules going forward. Compliance for AI marketing materials will become a core necessity for all cross-border brands, and the market for related compliance services will expand rapidly.

2. Current client pain points and business opportunities: A large number of Amazon sellers and brands hold large volumes of existing AI-generated materials, and generally face pain points of not knowing which materials require compliance adjustments or how to properly label content, with small and medium-sized sellers particularly confused. Service providers can launch AI material compliance audit services and compliance labeling services, and can also offer matching services connecting clients with real-life photo resources to replace AI materials, to seize this compliance-driven business opportunity and expand their business.

Following the entry into force of New York State’s new AI advertising regulation, cross-border e-commerce platforms have clarified directions for future operational adjustments and identified risk points that need to be addressed.

1. Current core demands from sellers: The vast majority of Amazon sellers have used AI-generated model materials, and now face widespread compliance risks. Sellers need platforms to quickly clarify compliance requirements, open labeling entries across all categories and content sections, and provide a sufficient grace period for adjustments. Currently, only A+ Content has a labeling entry, and core content areas such as main and sub images lack corresponding functionality, so demand for rule updates from sellers is very strong.

2. Risk mitigation and operational adjustment: Under the new regulation, platforms do not bear liability for violations as advertising intermediaries. However, if a large number of sellers are fined for violations, it will hurt seller retention and overall sales stability on the platform. Platforms can quickly roll out AI labeling entries across all content sections, release clear unified compliance audit standards, and offer a grace period for adjustments. This will not only help sellers complete compliance overhauls, but also improve the transparency of platform advertising content and mitigate overall operational risks.

New York State’s enactment and entry into force of a regulation requiring disclosure of AI-synthetic performers in advertising marks a new development in global regulation of AI applications in marketing, and carries high research value for studies of digital marketing compliance and AI industry governance.

1. New industry trends: AI-generated content has already seen large-scale commercial adoption in cross-border e-commerce marketing, with the vast majority of Amazon sellers using AI-generated models to cut marketing costs. Corresponding regulation has also quickly taken effect, indicating that a global compliance framework for commercial AI use is gradually taking shape. This is an important new milestone in the development of commercial AI.

2. Insights for research directions: This regulation raises a host of new questions worth exploring, such as whether AI editing of a real person’s face falls under the scope of regulation, how labeling AI-generated content impacts consumer purchase decisions, how to allocate responsibility between platforms and sellers in cross-border e-commerce scenarios, and how compliance costs should be shared for small and medium-sized businesses. The regulation adopts a targeted regulatory approach, only restricting AI-generated hyper-realistic humans rather than banning routine AI retouching, which also provides a research sample for other countries developing similar regulations in the future.