An item distributed without a sale price can still form part of a commercial campaign. Do not use the absence of a retail transaction as the whole explanation for its rights status.
WIPO describes IP licensing through the particular permissions granted in an arrangement. WIPO — IP Assignment and Licensing.
Describe the promotion
For a character giveaway, identify what will be made, how it will be presented and who will distribute it. The actual licence and relevant law need to be reviewed for that use.

Keep assumptions visible
A general product permission should not be expanded casually to every promotional activity. Obtain appropriate confirmation of unresolved scope questions before production or publication. This article provides no blanket rule that a free distribution is permitted or prohibited.

Source reviewed 25 October 2026. Interpretation and original diagrams: PLUSHIP / Qunhe. Examples are illustrative.
Related reading
A Character Voice Needs an Identifiable Permission Basis
A Subcontractor's Access to Character Files Needs a Defined Purpose
An AI-Generated Character Still Needs a Review of Its Actual Appearance
