Free gift with purchase video ad: terms on screen with 'free'
The FTC free-offer guide wants every condition beside the word free, not in a footnote. How to burn the terms into a gift-with-purchase clip with caption cues.
If your video ad says "free gift", put the condition on screen in the same cue, at the same moment: "Free tote with orders over $50. While supplies last." The FTC's free-offer guide asks for terms in close conjunction with the offer and says a footnote does not count as disclosure at the outset. Authored caption cues let you burn exactly that line, in one pass, at $0.20 per clip up to 60 seconds on Sume.
This is a summary of 16 CFR 251.1, read 2026-10-03. It is an FTC guide, not a statute, and this post is not legal advice.
What the guide says
The table is limited to provisions quoted from that page.
| Paragraph | What it says | What it means on screen |
|---|---|---|
| (b) | If an article is Free when another is bought, the buyer pays nothing for it and no more than the regular price for the other | Show the purchase requirement in the same line as Free |
| (b)(2) | Regular price means the price openly and actively sold at in the recent regular course of business, for about a 30-day period | Compare against a price you really charged for 30 days |
| (b)(1) | No recovering the cost by marking up the price or substituting inferior goods | Do not raise the main item's price to fund the gift; ship the gift as shown |
| (c) | Terms should appear in close conjunction with the offer; footnotes are not disclosure at the outset | One cue, not a tiny end card |
| (h) | A single size or kind should not carry a Free offer in a trade area for more than 6 months in any 12-month period | Put an end date on the clip |
Burn the terms into the clip
Send the finished clip's public URL and two or three cues. Keep the word free and its conditions inside one cue so they appear together and for the same length of time. Give the cue enough seconds to read: about 4 seconds for a 12-word line is a reasonable floor, though that is a guess of mine, not a rule from the guide.
The video captions docs say authored cues skip speech-to-text, so a music-only ad works. A silent clip sent without cues fails as caption_no_speech.
curl -X POST https://api.sume.com/v1/video-captions \
-H "Authorization: Bearer $SUME_API_KEY" \
-H "Content-Type: application/json" \
-H "Idempotency-Key: gwp-tote-oct-001" \
-d '{
"video_url": "https://media.sume.com/artifacts/example/ad.mp4",
"cues": [
{
"text": "Free tote with orders over $50",
"start": 1,
"end": 6
},
{
"text": "Free tote with orders over $50. While supplies last. Ends Oct 31",
"start": 6,
"end": 12
}
]
}'What Sume cannot check
Sume burns the words you give it. It does not read your price history, decide whether a gift is really free, or confirm that your checkout applies the offer. Compare the burned text with the live offer on the day the ad goes out, and re-burn if the threshold changes.
If the gift is deducted at checkout by a rule like Buy X get Y, the BOGO post maps those fields to on-screen lines.
Sources
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