United Kingdom · CAP Code · promotional claims
Free gift with purchase claims on UK landing pages — CAP literacy
“Free travel-size”, “bonus mask with every order”, “gift worth £40” — gift-with-purchase modules sit in hero banners, cart drawers and checkout upsells. Under CAP Code 3.7 consumers may treat them as objective facts about what they will receive. This guide helps UK marketers inventory GWP wording before publish.
Why GWP lines are claims, not decoration
CAP’s substantiation guidance applies to promotional promises consumers are likely to rely on. A gift module implies:
- A specific item (or choice set) will be supplied.
- It is “free” relative to the stated purchase condition.
- Any stated value or RRP is accurate and representative.
Inventory headline, subcopy, product-tile badge, cart banner and checkout reminder as separate rows — they often diverge after a merchandising tweak.
Common GWP patterns on landing pages
| On the page | Likely consumer takeaway | Register / evidence column |
|---|---|---|
| “Free gift with all orders” | Every checkout receives the gift | Exclusions, minimum spend, stock cap |
| “Worth £X” gift strip | Objective value claim | Basis of value, usual selling price |
| “While stocks last” | Limited availability qualifier | Must not contradict “guaranteed gift” elsewhere |
| “Choose your freebie” | Selection mechanics are material | SKU list, OOS substitute rules |
| Auto-added cart gift | Silent fulfilment promise | Tech spec + customer comms if gift OOS |
Rule 3.9 (material information) bites when the hero says “free gift” but T&Cs require a minimum basket, specific SKU, or new customers only — same contradiction habit as free delivery claims.
“Free” vs bundle pricing
If the main product price was increased to fund the gift, a “free” headline may need careful substantiation alongside bundle mechanics — see bundle and multi-buy pricing claims. Register whether the offer is a true addition or a restructured price.
Substitutes and out-of-stock
“Equivalent gift may be substituted” must be prominent if the advertised SKU is limited. A hidden warehouse note is not enough on the landing page consumers see pre-checkout.
Time limits
End dates belong near the headline if the module is time-limited — see limited-time offer claims and countdown timer literacy.
Pre-publish inventory habit
- Log each visible GWP line in the claim register with SKU and fulfilment owner.
- Cross-check cart and checkout — mobile breakpoints often drop the qualifier.
- Hold stock and value evidence before go-live.
- Run a free scan on staging — free scan.
Agency handoff: claim register agency template. Substantiation primer: advertising claim substantiation.
What CiteBefore does — and does not do
- Not ASA clearance — we inventory and flag gaps; we do not approve copy.
- Not stock-system auditing — we do not verify warehouse allocation.
- Not legal advice on promotional law beyond CAP literacy.
Questions
Is a free gift always a separate claim under CAP 3.7?
Often yes. Headlines like free gift with purchase or bonus serum included are usually read as objective promises about what the customer receives. Qualifications, stock limits and purchase thresholds must be clear and consistent with the headline.
What evidence belongs in the claim register for GWP?
SKU list, stock allocation, minimum spend, eligibility dates, substitute product rules, and delivery timing. Hold evidence before publish and re-scan if the hero module changes.
Does CiteBefore clear promotional offers?
No. CiteBefore inventories claims on a live URL and flags evidence gaps. ASA decides complaints; Copy Advice is a separate service.
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