Which AI use cases in manufacturing are high risk under the EU AI Act?

Annex III point 4(a) lists AI systems intended to be used to recruit or select natural persons, including to place targeted job advertisements and to analyze and filter applications. Ranking a company's own past applicants and new candidates against an open role, and deciding who a recruiter sees first, is filtering and evaluating candidates for that purpose.

Generating training content is not listed in Annex III. Providers of tools that generate synthetic audio, image, video or text content must mark the output as AI generated (with an exception for assistive editing that does not substantially alter the source), and deployers must disclose deep fakes, such as an avatar or voice that resembles a real person and would falsely appear authentic (Article 50(2) and (4), with the definition in Article 3(60)). If the same system evaluates learning outcomes or decides access to training that affects a person's work, Annex III point 3 (education and vocational training) and point 4 (employment) must be checked, and those parts can be high risk.

A system that advises engineers on the condition of equipment is usually minimal risk. Annex III point 2 lists AI systems intended as safety components in the management and operation of critical digital infrastructure, road traffic and the supply of water, gas, heating or electricity; if predictive maintenance acts on protection or control in a utility network, it can become high risk. Article 6(1) can also apply when the AI is a safety component of machinery or another product covered by Annex I legislation and that product must undergo a third party conformity assessment.

Annex III point 4 lists AI used for the recruitment or selection of natural persons (4(a)) and AI used to make decisions affecting promotion, or to allocate tasks based on individual behavior, personal traits or characteristics (4(b)). A marketplace that ranks employees for internal roles or allocates projects on the basis of inferred traits is therefore high risk. Recommending learning content or mentors to an employee who chooses freely is usually not. Deployers of the high risk part must inform workers' representatives and the affected employees before use (Article 26).

Inspecting products is not an Annex III use, so a system that only judges parts, welds or assemblies is usually minimal risk. Two designs change that. Under Article 6(1) it is high risk when both conditions hold: it is a safety component of a product (or itself a product) covered by the Union harmonization legislation in Annex I, and that law requires a third party conformity assessment of the product. For a production line the relevant product laws are the Machinery Regulation (EU) 2023/1230 and, for cars, the vehicle type approval regulations. Since the Digital Omnibus on AI, Regulation (EU) 2026/1744, moved the Machinery Regulation into Annex I Section B, where the vehicle type approval regulations already sat. Article 6(1) still classifies such a safety component as high risk, but under Article 2(2) only Article 6(1), Article 60a and Articles 102 to 112 of the AI Act apply directly. The requirements reach the system through the sectoral law instead: delegated acts amending Annex III of the Machinery Regulation, and type approval for vehicles. The AI Act rules for Article 6(1) high risk systems apply from 2 August 2028. An inspection system on the assembly line is usually not a safety component of the product it inspects. If it monitors and evaluates the performance and behavior of individual workers, for example by scoring who made an assembly error, it falls under Annex III point 4(b) and is high risk. Keep the output about the unit, not the person.

Classifying documents and extracting data for a person or process to use is usually minimal risk. Even inside an Annex III area, a system that only performs a narrow procedural task, such as splitting and classifying documents, can fall outside the high risk category under Article 6(3); the provider must document that assessment and register the system (Article 6(4) and Article 49(2)). The picture changes when extraction materially influences decisions in Annex III areas, such as eligibility for public assistance benefits (point 5(a)), creditworthiness (point 5(b)) or asylum, visa and residence permit applications (point 7), where the whole system must be assessed as potentially high risk. The Article 6(3) exception never applies when the system performs profiling of natural persons.

Annex III point 2 lists AI systems used as safety components in the management and operation of critical digital infrastructure, road traffic, or in the supply of water, gas, heating or electricity as high risk. An agent that only optimizes a process unit inside operating limits and safety systems that act independently is not obviously a safety component, while one whose failure would endanger the supply of gas, heating or electricity could be. Which side a given plant falls on depends on its design and use. The deployments recorded here are in Saudi Arabia and Japan, outside the EU market.

Classifying and summarizing text feedback is minimal risk. The tier changes if the system infers emotions from customers' voices or faces in calls or video: emotion recognition based on biometric data is listed as high risk in Annex III point 1(c) and triggers the Article 50(3) duty to inform the people exposed. Analyzing feedback from employees to evaluate individual workers moves it towards Annex III point 4(b), and emotion recognition in the workplace is prohibited by Article 5(1)(f), except for medical or safety reasons.

Translating and adapting commercial content is not an Annex III use and makes no decisions about people. When an organization uses a third party translation or generation tool, the use is minimal risk for the organization: the Article 50(2) duty to mark generated text in a machine readable way falls on the provider of that system, and beyond AI literacy no specific deployer obligations apply. When an organization builds and operates its own generating system and puts it into service under its own name, it is the provider and must mark the output, unless the exception for systems that only assist standard editing or do not substantially alter the input or its semantics applies. A faithful translation may fall within that exception; transcreation that rewrites the message for a market alters the semantics and is less likely to. Article 50(4) covers deepfakes and text published to inform the public on matters of public interest, not marketing translations. Consumer protection and advertising rules apply to the translated text as to the original.

Summaries, CRM suggestions and follow up drafts that the seller reviews are not an Annex III use and are minimal risk. Using call analysis to monitor and evaluate the performance and behavior of individual sellers, or to allocate leads to sellers based on their behavior or personal traits, is high risk under Annex III point 4(b). Inferring sellers' emotions from their voice is prohibited in the workplace by Article 5(1)(f). Emotion recognition applied to customers' voices is high risk under Annex III point 1(c), and Article 50(3) requires deployers to inform the people exposed to it.

Minimal for a system level register of systems and owners with no monitoring of individual employees; it is not listed in Annex III and is the instrument deployers use to meet obligations such as the Article 26 duties for high risk systems and the Article 49 registration of Annex III systems in the EU database. Limited where the plain language assistant that staff and auditors query is not obviously an AI system to its users: under Article 50(1) its provider must then design it so people are told they are dealing with AI. Possibly high risk under Annex III point 4(b) on worker management if the discovery process monitors or evaluates the behavior of individual employees rather than staying at the level of systems and owners.

A back office agent that turns business customers' order messages into draft sales orders does not decide on access to services, credit or employment, which is minimal risk. Article 50(1) applies to providers of AI systems intended to interact directly with natural persons. Reading inbound orders and sending a one way acknowledgment is a weak fit, but an agent that holds clarification exchanges with customers on WhatsApp or email does interact directly with the people who write, and those people must be informed they are dealing with an AI system unless that is obvious from the context.

Contract review and sourcing are not among the Annex III high risk uses, so an internal assistant that makes no decisions about natural persons is minimal risk (with the Article 4 AI literacy duty). If a negotiation bot chats directly with supplier staff, Article 50(1) applies and it must tell them they are dealing with an AI system, unless that is obvious from the context. Public authorities using AI in procurement should still check national public procurement rules on transparency and equal treatment of bidders.

Sequencing machines and orders is usually minimal risk. The design decides the tier if the same system also allocates tasks to individual workers based on their individual behavior or personal traits or characteristics, or monitors and evaluates their performance and behavior in a work relationship; that use falls under Annex III point 4(b) of the EU AI Act. Keep order and machine sequencing separate from any such worker task allocation or performance evaluation to stay outside that category.

Article 50(1): staff must know they are interacting with an AI system, unless that is obvious from the context. Answering maintenance questions is not an Annex III use. It would become high risk under Annex III point 4(b) if the usage data were used to monitor and evaluate the performance of individual workers, so keep usage analytics aggregated.

Generating presenter video is not listed in Annex III. Providers of tools that generate synthetic video must mark the output as AI generated, and deployers must disclose deep fakes, such as an avatar or cloned voice of a real executive that would falsely appear authentic (Article 50(2) and (4)). The tier changes only if the same system also decides on access to work or services, which these deployments do not describe.

Forecasting a company's cash flows is not listed in Annex III and makes no decision about a natural person, so the forecasting model itself carries no obligations beyond AI literacy (Article 4). The conversational layer interacts directly with treasury staff, so under Article 50(1) they must be informed that they are dealing with an AI system unless that is obvious from the context. Without a conversational layer the use case is minimal risk.

Inline translation and rule based content targeting for internal communication do not decide on hiring, pay, promotion or termination and are not listed in Annex III, so they carry no specific obligation under the EU AI Act beyond general AI literacy, unless a deployer adds a feature that scores or ranks individual workers, which would then need separate assessment. A Blits.ai agent built on top of this platform is a conversational AI system, so it carries the Article 50 transparency duty to disclose that employees are interacting with an AI system, regardless of tier.

The system scores transport lanes, shipments and suppliers, not natural persons, so it does not fall under an Annex III high risk category. It does not interact with the public and does not publish AI generated content, so it does not trigger the Article 50 transparency duty either. It stays minimal risk as long as its output only informs a human procurement or logistics decision.

The system analyzes shelves and products, not natural persons, and makes no decision about a person's access to a service, a job, credit or benefits, so it falls outside Annex III. If camera placement or software is changed to identify or track individual shoppers or staff, the analysis changes and biometric identification rules would apply.

Matching a company's own incoming payments to its own open invoices is a back office finance operation. It is not listed in Annex III and does not decide a natural person's creditworthiness or eligibility for a service, so it is minimal risk and the AI literacy duty of Article 4 applies. Using deduction or payment behavior to score an individual sole trader's creditworthiness would need a fresh risk assessment.

Searching for and profiling companies as potential suppliers is not listed in Annex III and does not decide on individuals, so only AI literacy duties apply. Supplier contacts are personal data, which brings GDPR duties on how they are collected and kept. Using the tool to profile individual people, for example sole traders or workers, would need a separate assessment.

The system optimizes promotion terms between a manufacturer and a retailer; it does not decide a natural person's access to credit, employment, essential services or a regulated product, so it falls outside Annex III. It would need reassessment if a manufacturer used the same technique to set individually targeted prices or offers for identified consumers.

Tracking contractual obligations and sending reminders is not among the Annex III high risk uses; an internal tool that extracts terms and alerts an owner makes no decision about a natural person's access to a service, employment or credit, so it is minimal risk under the EU AI Act, with the Article 4 duty to give staff who operate it appropriate AI literacy. The DORA and APRA CPS 230 entries below apply only when the deploying organization is itself a regulated bank, insurer or other financial entity; for other industries they do not apply.

Forecasting a company's own foreign currency flows is not listed in Annex III and makes no decision about a natural person. The model is used by treasury staff and does not interact with the public, so the obligations are limited to AI literacy (Article 4).

Drafting business quotes for a seller to review is not an Annex III use and does not interact with the customer as an AI system. It would need a fresh assessment if the system set individual consumer prices or terms in areas such as credit or insurance, where Annex III point 5 can apply.

Classifying the organization's own purchase lines into categories is not listed in Annex III and is used internally by procurement staff, so no specific obligations apply beyond AI literacy. The data can still contain personal data, for example in purchasing card and expense lines, which brings GDPR duties. Using the classified card and expense lines to monitor or evaluate individual employees would move the system towards Annex III point 4 (employment and worker management) and a high risk assessment.