Do I need a registration certificate to post a "test drive" car body advertisement?

After investigation, the business scope of a certain company is: Guangqi Honda brand automobile sales and services, automobile decoration, and automobile parts sales. Company A has not applied for an outdoor advertising registration certificate. Differences of opinion Industrial and commercial law enforcement officials have different views on the nature of Company A’s behavior of publishing car body advertisements and whether the company needs to apply for an outdoor advertising registration certificate. The first opinion is that Company A’s behavior is unauthorized publishing of outdoor advertising, which violates Article 5, paragraph 1, of the Regulations on the Registration and Management of Outdoor Advertising. The Outdoor Advertising Registration Certificate... (2) Advertising drawn, posted, and hung on the surface of vehicles, floating objects on water, aerial devices, inflatables, and models" is an unauthorized release of outdoor advertising. According to Article 18 of the Regulations on the Registration and Management of Outdoor Advertising, “Any unit or individual that violates the provisions of Articles 5 and 11 and publishes outdoor advertisements without registration shall have their illegal gains confiscated by the industrial and commercial administration authorities and shall be fined not more than 30,000 yuan. If the company fails to complete the registration procedures within the time limit, it will be ordered to stop publishing. Company A may be ordered to complete the registration procedures within a time limit and be fined not more than 30,000 yuan. The second opinion is that Company A’s behavior of posting advertisements on its vehicles in its own compound (legally controlled area) is self-designed outdoor advertising and complies with Article 5, Paragraph 2 of the Regulations on the Registration and Management of Outdoor Advertising, which states that “at the registered address of this unit” If it is set up in the legally controlled zone of legal business premises, self-designed outdoor advertisements that promote the name, logo, business scope, legal representative (person in charge), and contact information of the unit do not need to apply to the industrial and commercial administration for outdoor advertisements. Registration. Unless otherwise provided by local laws and regulations, there is no need to apply for an outdoor advertising registration certificate. This is because the sales of Guangqi Honda vehicles are part of the approved business scope of Company A, and the test drive is a sales service item approved by the business scope. Case Analysis: Whether Company A needs to apply for an outdoor advertising registration certificate when publishing car body advertisements, two questions need to be clarified: 1. Whether the advertisement involved in the case is a self-designed outdoor advertisement. The so-called self-installed outdoor advertisements refer to those that are set up at the unit’s registered address and legal control areas of its legal business premises, unless otherwise provided by local laws and regulations, and that have a negative impact on the unit’s name, logo, business scope, legal representative (responsible person) people) and contact information for promotion. According to the above definition, Company A’s outdoor advertisement “Guangqi Honda Test Drive” is a self-designed outdoor advertisement. 2. Whether the advertisement is placed in a legally controlled area. The legal control zone refers to the area within the planning red line of a building in the sense of architectural planning. There are two situations: one is that the advertisement is directly attached to the building itself, and the other is that the advertisement is separated from the building itself, but is still within the approved planning land scope of the building. Obviously, Company A’s outdoor advertisement “Guangqi Honda Test Drive” was placed on a company’s own car parked in a company’s yard and was set up in a legally controlled area. Based on the on-site situation of this case, the author agrees with the second opinion. Company A does not need to apply for an outdoor advertising registration certificate, and the industrial and commercial authorities do not need to punish the parties involved. Test drive is an effective car marketing tool and is very common in the current car sales market. Test Drive During the test drive, the car will definitely drive out of the gate of Company A and onto the road. Therefore, regarding the issue of "test drive" body advertising, an administrative proposal should be issued to the parties concerned, suggesting that the parties choose whether to apply for an outdoor advertising registration certificate from the industrial and commercial administration authorities based on their needs and the content of the slogans posted on the vehicle body. □Wang Xiangjie