Do product recommendation widgets count?

Usually not, though this specific scenario isn't spelled out with a named example in the Commission's draft guidance we've reviewed — what follows is our best-reasoned application of the definitions, not a settled ruling.

Article 50's two duties most relevant to SMEs are each keyed to a specific behavior. The chatbot disclosure duty (Article 50(1)) requires a natural person to interact directly with your AI — a conversational or voice exchange. The generative-system marking duty (Article 50(2)) requires your system to generate new audio, image, video, or text output, under your brand, for others to use.

A standard "customers who bought this also bought…" widget, or an algorithmic ranking/recommendation engine, typically does neither. It selects and ranks existing catalog items rather than generating new content, and it isn't a conversational interface a shopper is "talking to." On that reading, most recommendation widgets fall outside Article 50 entirely.

Two things would change the answer. If the widget has a chat-like, conversational personality that responds to a shopper's questions about products, that tips it toward the chatbot disclosure duty. If it generates genuinely new descriptive text or images — AI-written personalized product blurbs, for instance — shown to the shopper under your brand, that tips it toward the generative-marking duty (subject to the same provider-only scope as any other generative system).

If your widget sits anywhere near that line — conversational, or generating rather than selecting content — it's worth running through the free check rather than assuming it's out of scope by default.

A growing middle case worth flagging on its own: hybrid widgets that rank existing products but also generate a short natural-language explanation of the pick ("recommended for you because…") sit closer to the generative side than a plain ranked list does. Whether that specific pattern counts isn't addressed by the source material we've verified either, so treat it the same way — reasoned, not certain, and worth checking rather than assuming.