AI Labeling in Your B2B Shop: 5 Checkpoints Before December 2, 2026

A mid-sized wholesaler has been running an AI-powered customer service assistant in its online shop for months. Nobody in the company knows for sure whether the tool meets the new transparency obligations of the EU AI Act, who legally counts as the deployer, or what to do if a regulator comes asking. This scenario is far from unusual. On December 2, 2026, the last transition period for existing systems expires. This article gives management five concrete checkpoints.

Why the EU AI Act now affects your online shop

Since August 2, 2026, the transparency obligations in Article 50 of the EU AI Act (Regulation (EU) 2024/1689) have been binding. Chatbots and similar systems must disclose that users are interacting with an AI, unless that is already obvious. Deceptively realistic AI-generated images, videos, or audio, so-called deepfakes, must be disclosed as such. Providers of generative AI systems must also mark their output in a machine-readable way. For systems that were already on the market before August, a transition period runs until December 2, 2026.

Violations can lead to fines of up to 15 million euros or 3 percent of worldwide annual revenue, whichever is higher. For an overview of all the obligations that were already foreseeable in the spring, see our article on the EU AI Act for B2B shop operators. This article is not legal advice. It gives management a structured basis for review.

What many B2B operators get wrong

The most common misconception is: "We only use AI internally, so this does not affect us." That is not quite right. What matters is whether an AI system interacts directly with people, meaning customers, buyers, or visitors to your shop. That is exactly where the labeling requirement for chatbots and the disclosure of deepfakes apply.

A second misconception concerns AI-generated content: product descriptions written with AI assistance and then reviewed by an editor are not automatically subject to labeling. The regulation draws a distinction here. If, on the other hand, you publish AI-generated text on matters of public interest without human review and editorial responsibility, you must label it.

For many B2B shops, the real risk lies elsewhere: purchased shop extensions, service platforms, or chat solutions often come with AI features that nobody noticed in day-to-day operations. Whether your company counts as a provider or a deployer under the EU AI Act determines who carries which obligation. Many contracts do not yet address this question.

5 checkpoints for your B2B shop before the deadline

1. Check your chatbot and customer service assistant: Does your shop use an AI-powered chat, an ordering assistant, or a virtual contact person? Make sure it clearly identifies itself as AI no later than the first interaction. A hidden note in your terms and conditions is not enough.
2. Catalog AI images and product videos: Do you use AI-generated product images, animations, or voice recordings in your shop or in campaigns? You must visibly disclose deceptively realistic content. The machine-readable marking has to come from the tool that generated it. Ask your vendors whether this will be in place by December 2.
3. Clarify contracts with tool vendors: Who is the provider and who is the deployer? This distinction determines who carries which obligations. Review your contracts with software vendors for corresponding clauses and add them where they are missing.
4. Take inventory of every AI tool in your shop: Create a list of all AI features in use, from product recommendations to automated price adjustments to chatbots. Many Shopware extensions and external services contain AI components that nobody thinks of as AI in daily operations. Our Shopware development team can support you with the technical inventory.
5. Assign responsibility within your team: Name one person who is accountable for meeting the transparency obligations and who can answer questions from regulators. Make sure the employees who use AI tools understand their limits.

Conclusion: review now, before the deadline creates pressure

December 2, 2026, is not a theoretical date. That is when the transition period for existing systems ends and the transparency obligations apply in full, including the risk of fines. If you start a structured review of your AI tools now, you avoid time pressure and protect your customers' trust. If your team lacks the capacity, an external e-commerce department can take over the inventory.

Since 1999, Commerce Partner has helped mid-sized manufacturers and wholesalers develop their online shops securely. If you want to know which AI features in your shop are affected and how to tackle the requirements in a structured way, get in touch: you can request a free strategy consultation directly through our contact page.