Retouched Image Label Rules by Country

Norway

Since July 1, 2022, advertising needs a label when retouching or a filter changes a person's body shape, size or skin. The regulator counts the head and face as part of the body, and there's no minimum, so removing one pimple counts.

• No label needed: makeup, styling and lighting before the shot; the color of hair, teeth or eyes; general brightness and contrast; anything that isn't a person.
• The label is a standard design that covers about 7% of the image, normally in the upper left corner.
• It applies to advertisers and to people who create ads for pay, including photographers, and to foreign advertisers targeting Norwegian consumers.
• If the regulator suspects retouching, the advertiser has to prove otherwise, so keep the original files.

Source: Norwegian Consumer Authority guideline.

France

Since October 1, 2017, commercial photos of models whose silhouette has been slimmed or thickened with image software must carry the words "photographie retouchée" or "photo retouchée".

• It covers posters, online ads, press, advertising mail and flyers, but not TV ads.
• The advertiser is responsible for checking, even for images bought through suppliers.
• The fine is €37,500, and can rise to 30% of what was spent on the advertising.

Source: summary by law firm CMS, in French.

Israel

A law in force since the start of 2013 requires advertisers to clearly mark images that were digitally altered to make a model look thinner. It also sets a minimum body mass index of 18.5 for models. Source: The Times of Israel.

United Kingdom

We didn't find a retouching label requirement in the UK, but ads there must not mislead. In 2012 the advertising regulator upheld a complaint against a Dior mascara ad with retouched lashes, because Dior hadn't shown that the look could be achieved with the product alone. Retouching wasn't banned as such. The issue was exaggerating what the product does.

Source: Advertising Standards Authority ruling. That ruling is old, so check the current code.

United States and New York

We didn't find a US federal law that requires a retouching label. General rules against deceptive advertising still apply. New York has two newer laws, which deal with artificial people rather than ordinary retouching:

• Since June 9, 2026, ads must clearly disclose a "synthetic performer", a digitally created figure not recognizable as a real person, when the advertiser knows one is used. Penalties are $1,000 for a first violation and $5,000 after that. Source: Cooley.
• Since June 19, 2025, the Fashion Workers Act has required clients to get a model's clear written consent before creating or using a digital replica of them. Source: Morgan Lewis. One law firm's summary says routine edits such as color correction and minor retouching aren't covered: Legal 500.

What this means for a job

• Tell your retoucher every market the image will run in.
• Keep the original files, and a note of what changed on the person's body, face and skin.
• Agree who is responsible for adding any label: the brand, the agency or the publisher.
• If the image shows what a product does, make sure the retouching doesn't exaggerate it.

The how to brief a retoucher template has a line for this, and AI vs human retouching covers generated images.