Amazon Synthetic Performer Image Labeling: XMP Metadata Compliance Guide for Sellers
What happened and why it matters
On July 22, 2026, Amazon notified all third-party sellers: product images and A+ Content containing photorealistic AI-generated people must include the keyword contains-synthetic-performer in their XMP metadata dc:subject field before upload.
This comes from New York General Business Law Section 396-b, effective June 9, 2026, which requires commercial content with AI-generated realistic human likenesses to be labeled. Amazon is passing that compliance burden to sellers — the platform won’t detect or add the tag for you.
What needs tagging and what does not
Only photorealistic AI-generated human figures need the tag. Everything else is exempt.
| Scenario | Tag required? | Reason |
|---|---|---|
| AI-generated photorealistic human model | Yes | Meets the synthetic performer definition |
| AI-generated realistic hands or partial body | Yes | Still a photorealistic human likeness |
| AI-generated person in A+ Content | Yes | A+ Content falls under the same rule |
| Real human model, photographed | No | Not AI-generated |
| Real photo with AI edits (retouching, background removal) | No | Base image is a real person |
| AI-generated cartoon or illustrated character | No | Not photorealistic |
| AI-generated product-only image (no people) | No | No human likeness involved |
Gray areas exist — an AI-generated person shown only as a silhouette or heavily blurred might not qualify as photorealistic, but Amazon has not published detailed boundaries. When in doubt, add the tag. There is no downside to over-tagging.
Adding metadata with ExifTool
ExifTool is a free, open-source command-line utility for image metadata, available on macOS, Windows, and Linux. Tag a single image:
exiftool -XMP-dc:Subject+="contains-synthetic-performer" your-image.jpgThe += operator appends without overwriting existing keywords. Tag an entire folder:
exiftool -XMP-dc:Subject+="contains-synthetic-performer" /path/to/images/Verify with exiftool -XMP-dc:Subject your-image.jpg. Watch out for image editors and online compression tools that strip XMP data on export — make tagging the last step before upload.
Adding metadata with Adobe Bridge and Photoshop
In Adobe Bridge, select target images, open the Keywords panel, click the new keyword button, type contains-synthetic-performer, and check the box. Select all images first for batch application.
In Photoshop, go to File then File Info, switch to the IPTC tab, type contains-synthetic-performer into Keywords, and click Add. One image at a time, so ExifTool is faster for batches. Either way, run ExifTool verification afterward — Bridge occasionally shows a keyword as applied without writing it to the file.
What happens if you skip it
Amazon did not list specific penalties, but past compliance enforcement suggests image rejection, listing suppression, or a Policy Warning. The legal risk is larger — Section 396-b is a consumer protection statute, and violations can result in civil penalties.
Adding one ExifTool command to your upload workflow takes minutes. Compared to a suppressed listing during peak season, that time cost is trivial. If you use AI-generated people in product images, tag them now.
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