South Korea has recently taken an important step in this area by introducing new rules aimed at increasing transparency in cosmetics advertising. The measures focus particularly on the use of AI-generated characters that appear to be experts or trusted authorities.
Why Are Authorities Taking Action?
Advances in generative AI have made it possible to create highly realistic images, videos, and voices that are often difficult to distinguish from real people. While these tools can offer creative opportunities for brands, they also raise concerns when consumers cannot easily identify whether a recommendation comes from a real person or a computer-generated character.
Regulators have observed a growing use of AI-created endorsements in online marketing, including virtual doctors, scientists, beauty specialists, and even celebrity lookalikes. Such content may influence purchasing decisions by creating a false impression of expertise, personal experience, or product approval.
The new Korean measures seek to ensure that consumers understand who—or what—is actually speaking in an advertisement.
New Restrictions on AI-Generated Endorsements
A recent amendment to South Korea’s cosmetics legislation introduces specific rules regarding AI-generated advertising content.
The key principle is straightforward: cosmetic advertisements must not use AI-generated voices, images, or videos in a way that could lead consumers to believe that qualified professionals are personally recommending, certifying, or using a product when this is not the case.
The restriction is particularly relevant for representations of healthcare professionals, academics, and other experts whose perceived authority may influence consumer trust.
Importantly, the amendment does not prohibit the use of artificial intelligence in advertising altogether. Instead, it confirms that AI-generated content is subject to the same advertising standards that already apply to traditional marketing materials.
When Can AI Advertising Become Misleading?
The new rules reflect a broader regulatory view that the technology used to create content does not change the advertiser’s responsibility for its accuracy.
Examples of potentially problematic practices include creating fictional endorsements that appear to come from real individuals, generating images that exaggerate product performance, fabricating user testimonials, or presenting virtual medical or scientific figures as genuine experts without clearly informing consumers.
In each of these cases, the concern is not the use of AI itself but the risk that consumers may be misled about the source, credibility, or effectiveness of the advertised product.
Transparency Becomes a Regulatory Requirement
Alongside the changes affecting cosmetics advertising, South Korean authorities have also introduced new guidance on how AI-generated endorsers should be presented to the public.
Under the updated approach, virtual characters used to recommend or promote products must be clearly identified as such. The objective is to ensure that consumers immediately understand they are viewing a digital creation rather than a real person.
This transparency requirement applies across different advertising formats, although the practical implementation varies depending on the medium used.
For written content such as blog posts or online community articles, the presence of a virtual character should be disclosed prominently, either in the title or at the beginning of the text. Images containing AI-generated endorsers should also include a visible indication that the depicted individual is a virtual person.
For photographs, videos, and other visual formats, the disclosure should remain visible throughout the appearance of the virtual character and be presented in a way that can be easily distinguished from the background.
Disclosure Alone Is Not Enough
One particularly interesting aspect of the new guidance is that simply labeling a character as virtual does not automatically make an advertisement compliant.
If a virtual person appears to describe personal experiences with a cosmetic product, those statements must still be truthful and not create a misleading impression. A disclaimer cannot be used to justify fabricated experiences or unsupported claims.
This reflects a broader regulatory principle that transparency and truthfulness are complementary obligations rather than alternatives.
Part of a Larger Trend in AI Governance
The cosmetics sector is only one part of a wider effort by South Korean authorities to address the challenges created by generative AI.
Recent regulatory initiatives have increasingly focused on making AI-generated content identifiable to the public and improving oversight of digital marketing practices. Authorities have also explored technological solutions, including AI-assisted monitoring systems designed to detect potentially deceptive online advertising.
Particular attention is being paid to sectors where consumer health and safety are closely linked to advertising claims, such as cosmetics, food supplements, and pharmaceutical products.
What Should Cosmetic Companies Do?
For cosmetic manufacturers, brand owners, and marketing agencies, these developments highlight the growing importance of governance around AI-generated content.
Businesses using virtual influencers, digital avatars, or AI-created experts should review their advertising strategies to ensure that consumers can clearly recognize when content has been generated artificially. Internal review procedures may also need updating to assess not only traditional advertising claims but also the presentation and disclosure of AI-generated characters.
As regulators around the world continue to develop rules for artificial intelligence, South Korea’s latest measures provide an early example of a transparency-focused approach. Rather than restricting innovation, the objective is to ensure that new technologies can be used responsibly while preserving consumer trust and fair competition in the marketplace.
