On November 3, Shanghai's Jiading district market supervision bureau confirmed it has opened a formal case against Shanghai SAIC Volkswagen Automobile Sales Co., the sales and operating entity behind SAIC Audi, over complaints about the company's "buy one get one" promotion [1][2]. The case is an investigation with no finding attached: no violation has been determined, and SAIC Audi has not publicly responded [1][2]. What the episode settles, before any ruling, is the part that matters at checkout: a gift promise is worth what the seller put in writing before payment — what the gift is, its specification, how many, until when, and how it will be delivered. Chinese promo rules spell out that list, and the disclosed version of the promise is the one that binds.
The complaints trace back to October 11, when Zheng Qinwen beat Andreeva 2:0 in the China Open women's singles final to become the tournament's first homegrown women's singles champion. SAIC Audi's official account posted that evening under the title "Congratulations to Qinwen on the title! Buy one get one across the full AUDI lineup," with poster copy reading "buy one get one across the full lineup" [1]. Clicking through, readers found the gift was a 1:18 scale model of the car, and "full lineup" covered only the two letter-badge AUDI electric models, the E5 and E7X — not the four-ring Audi models the company also sells [1][2]. A salesperson put the model's value at "roughly under 1,000 yuan" when the reporter asked [2]. On October 13 the title was amended to add "model car gift," and the poster copy changed to "buy the vehicle model, get the same-model model car" [1].
Before payment: the five particulars that bind
China's Advertising Law requires an advertisement that offers a gift with a purchase to state clearly the gift's type, specification, quantity, period and how the gift is given; anything the law requires to be disclosed must also be clear and legible [4]. SAMR's Order No. 32, in force since December 1, 2020, treats gift-with-purchase as a regulated form of prize-attached sales — sales promotions where buyers receive prizes or gifts — and requires the seller, before the promotion starts, to publish the gift's name, type and quantity, its price, the redemption time, conditions and method, the delivery method, and the organizer's contact [3]. The order bars changing those terms or attaching extra conditions unless the change favors the consumer — which is why the disclosed terms are worth saving before payment [3]. Promotional information must be truthful, accurate and clearly displayed, and a non-cash gift is valued at the market price of similar goods [3].
The October 13 amendment moved the gift into the headline: "buy one get one" became "buy one get one — model car gift" [1]. The post's body text had noted the gift in small print from the start, according to the lawyer's account — so the dispute is about how prominently the gift was disclosed, not whether it was disclosed at all, since the law's standard covers both what is stated and how legible it is [2][4]. Lawyer Zhu Rubi, senior partner at Guangdong Guanghe (Longgang) law firm, analyzed that the gap between the headline and the gift may implicate the disclosure duty and, if readers were misled, Article 28's definition of false advertising — while stating that determining illegality belongs to the market regulator, not to legal commentary [2].
After payment: the disclosed terms are the deliverable
Once an order exists, the disclosed promise stops being marketing and becomes the delivery standard. Order No. 32 requires a seller who makes a discount or gift promise through advertising, product descriptions or sales pitches to honor it [3]; a seller who does not deliver according to the information disclosed to consumers is treated as having run a false prize promotion [3]. Where no other law or regulation provides a penalty, breaking the order's provisions can bring a correction order and a fine of up to three times illegal gains, capped at 30,000 yuan, or up to 10,000 yuan where there are none [3]; Article 27 of the order routes violations of its prize-promotion rules — the list that includes the false-prize-claim item — to the penalties in Article 22 of the Anti-Unfair Competition Law [3], and an advertisement that violates the disclosure duty carries a fine under 100,000 yuan and a cease-publication order under Article 59 of the Advertising Law [4]. Those figures describe what the rules allow, not what any regulator has decided here.
The route consumers used is also on record. Shanghai's consumer hotline registered the complaints about the post and referred them to the market regulator [1][2]; the bureau's formal case followed. That route — registering the complaint so it is referred to the market regulator — is open to any buyer holding the disclosed terms and the order record. Customer service described "AUDI" as covering only the letter-badge sub-brand lineup; that explanation is the company's account, not a regulator's [2].
At the US border: free items still get declared
The same written-record logic follows the parcel across a border. For goods imported into the United States, CBP puts the importer's duties on the buyer: "When you buy goods from foreign sources, you become the importer." The declaration needs a full, accurate description of the item in English — CBP calls this a legal requirement — plus the quantity, the purchase price in US dollars for both unit and total, the weight, and the country of origin; giving misleading or inaccurate information about the item and its value is illegal, and the importer is the party who could face legal action and fines [5]. A promotional gift in the box has a description and a value like anything else in the shipment, and CBP's checklist draws no exemption for items that cost the buyer nothing. Mail shipments valued under $2,500 usually clear as mail entries, and declared values under $800 ($100 for bona fide gifts) generally clear without extra paperwork — thresholds CBP frames as paperwork rules while reserving the right to require formal entry for any import [5]. A clearance threshold is not a duty exemption, and nothing on the page exempts an item the buyer paid nothing for.
What the case settles — and what only the regulator can
The investigation is open, and whether the promotion broke the rules is a determination that sits with the market regulator [2]. What a buyer can use today is fixed in national rules that predate this case [3][4]. The report also places the case in a wider regulatory push: in March 2026 SAMR issued a notice on strengthening supervision of qualifying language in advertising and began a six-month campaign against "misleading big-print, small-print" ads, citing examples such as a "2.98 s" acceleration claim footnoted to exclude launch time [1]. For any promotion shaped like this one, the enforceable promise is the disclosed one — and where those particulars are missing or hard to find before payment, that gap is the red flag a buyer can act on.