Key Takeaways
The core point. Temu is a low-price shopping app that uses strong attention hooks: games, rewards, and “free” offers that often depend on conditions.
What is true about minimums. Temu’s own terms say there may be a minimum purchase amount to place an order, and that the conditions are shown on the product detail page before checkout.
Who runs what. Temu’s U.S. terms describe the operator as Whaleco Inc. in Delaware, United States (North America). Public reporting and filings connect Temu to PDD Holdings, a major e-commerce group with roots in China (Asia).
Why the “free” feeling is so strong. The design pattern is simple: curiosity first, checkout later. That is not a mistake. It is a conversion strategy.
What regulators flagged in two places. In September 2025, U.S. regulators announced an order and a civil penalty tied to seller transparency duties. In July 2025, European Union (Europe) regulators said Temu had a high risk of illegal products appearing on the platform, based on their own shopping tests.
Story & Details
The moment “free” stops being free. The attraction is easy to understand. A screen shows a reward, a countdown, or a box of “free” items. It feels like savings. It feels like winning. Then a detail appears late: a minimum cart value, a condition, or a rule that only shows up close to checkout. Temu’s terms spell out that a minimum purchase amount may apply, and that the conditions will be disclosed on the product page before an order is placed. That statement fits the common experience: the rule exists, but it can feel buried in the flow.
Why the mind keeps tapping. The pressure is not only price. It is structure. Games, coupons, spins, time limits, and “almost there” progress bars push a basic brain loop: see reward, chase reward, spend to finish the chase. Behavioral science calls this variable reward. The exact prize and the timing change, so the brain stays alert and keeps checking. The technique is common in apps that want repeat opens. It can be useful for learning or fitness. In shopping, it can turn “I do not need this” into “I might lose a deal.”
The shopping list that grows by itself. It often starts with harmless curiosity: a low-cost watch, a wallet, guitar picks, a power bank, a phone accessory, a smartwatch, a pressure-washer part, or a projector screen. Nothing looks expensive alone. The cart adds up quietly. That is why “free” items can be powerful: they feel like savings, yet they can be a lever to reach a minimum and trigger a purchase that would not happen otherwise.
Who owns the wheel. Temu’s U.S. Terms of Use say the agreement is between the user and Whaleco Inc., a Delaware company in the United States (North America). Beyond the operator, the bigger “who decides” question is about corporate control. Public reporting describes Temu as a Chinese online retailer and says it is owned by Pinduoduo, a well-known e-commerce business in China (Asia). In public filings for PDD Holdings, Lei Chen and Jiazhen Zhao are listed as top leaders. A filing in April 2023 announced Zhao as co-chief executive officer alongside Chen. Another filing dated December 2025 shows both Chen and Zhao signing as co-chairmen and co-chief executive officers. A separate shareholder letter from March 2021, signed by the founder Huang Zheng, described stepping down from the board and removing special voting rights attached to his shares. That combination of facts points to a simple picture: day-to-day direction is in the hands of current top executives and the board, not in a single founder’s super-vote mechanism.
What can be known, and what cannot. Public filings can show titles, governance changes, and sometimes office locations. They do not reliably prove where an executive lives day to day. For Lei Chen and Jiazhen Zhao, public documents describe roles and responsibilities, including a focus on China operations (Asia) in one leadership statement, but they do not provide a dependable answer to personal residence.
Regulators and the word “transparency.” In September 2025, the U.S. Federal Trade Commission announced a proposed order and said Temu would pay a civil penalty tied to alleged violations of the INFORM Consumers Act. The U.S. Department of Justice also announced an injunction and the same civil penalty. The core theme was marketplace transparency: making it easier for shoppers to identify and contact certain high-volume third-party sellers, and making reporting mechanisms easy to find and use.
Regulators and the word “risk.” In July 2025, the European Commission said it had preliminary findings that Temu breached a duty under the Digital Services Act to properly assess the risks of illegal products spreading on its marketplace. The Commission pointed to its own mystery shopping that found non-compliant products, including baby toys and small electronics. Reporting at the time described the same issue in plain language: shoppers in the European Union (Europe) could be exposed to illegal or unsafe items, and the platform could face major penalties if final findings confirmed violations.
A tiny Dutch mini-lesson for real life shopping moments. Two short sentences are enough for a calm boundary in the Netherlands (Europe), even while using an English interface.
Ik wil Temu verwijderen. This is used for a direct personal choice about removing an app. Word-by-word: Ik means I. wil means want. Temu is Temu. verwijderen means remove or delete.
Het is gratis, maar er is een minimum bedrag. This is used when something is presented as free but has a condition. Word-by-word: Het means it. is means is. gratis means free. maar means but. er is means there is. een means a. minimum means minimum. bedrag means amount. A natural variant in the same tone is: Er is een minimum bestelling, which keeps the meaning and is common in everyday speech.
Conclusions
The plain truth about the “free” promise. The best way to describe Temu’s “free items with free shipping” feeling is simple: it can be real, and it can still cost money. The key detail is the condition. Temu’s own terms say minimum purchase rules may apply and are disclosed on product pages before the order is placed.
What “who owns it” really means. Temu is presented in its terms as operated by a U.S. company, while public reporting and filings tie it to a larger group rooted in China (Asia). Corporate power is mostly board-and-executive power: titles, votes, and governance changes, not the loudness of ads or the brightness of coupons.
What a shopper can take away today. When an app makes spending feel like saving, the best tool is not outrage. It is clarity. Read the rule that turns “free” into “minimum.” Notice the game layer. Then decide, on purpose, whether the app belongs on a phone.
Selected References
[1] Temu | U.S. | Terms of Use — https://www.temu.com/terms-of-use.html
[2] Temu | Terms of Use (minimum purchase language shown) — https://www.temu.com/de-en/terms-of-use.html
[3] Federal Trade Commission press release on INFORM Consumers Act allegations and civil penalty — https://www.ftc.gov/news-events/news/press-releases/2025/09/online-marketplace-temu-pay-2-million-penalty-alleged-inform-act-violations
[4] U.S. Department of Justice press release on civil penalty and injunction — https://www.justice.gov/opa/pr/temu-agrees-2m-civil-penalty-and-injunction-alleged-violations-inform-consumers-act
[5] European Commission press release on Digital Services Act preliminary findings — https://digital-strategy.ec.europa.eu/en/news/commission-preliminarily-finds-temu-breach-digital-services-act-relation-illegal-products-its
[6] Associated Press report on the European Union action and Temu’s ownership description — https://apnews.com/article/caf2ba372cc0526a663d405868fd5819
[7] U.S. Securities and Exchange Commission filing announcing Jiazhen Zhao as co-chief executive officer in April 2023 — https://www.sec.gov/Archives/edgar/data/1737806/000110465923041119/tm2311344d1_6k.htm
[8] U.S. Securities and Exchange Commission filing showing signatures and titles for Lei Chen and Jiazhen Zhao in December 2025 — https://www.sec.gov/Archives/edgar/data/1737806/000110465925122765/tm2533961d2_6k.htm
[9] Pinduoduo shareholder letter by Huang Zheng discussing governance and voting rights in March 2021 — https://www.globenewswire.com/news-release/2021/03/17/2194340/0/en/Pinduoduo-2021-Shareholder-Letter.html
[10] Federal Trade Commission video on safer online shopping — https://www.youtube.com/watch?v=hnaAELBprmI
Appendix
Behavioral design: The use of triggers, rewards, and friction to guide what a person does in an app, often to increase time spent and purchases.
Dark patterns: Interface choices that nudge a user toward actions that help the seller more than the user, such as making costs clearer only near the end.
Digital Services Act: A European Union (Europe) law that sets safety and transparency duties for online platforms, including duties tied to illegal goods.
Federal Trade Commission: A United States (North America) agency that enforces consumer protection and competition laws.
Gamification: Adding game-like features, such as streaks, spins, and progress bars, to keep attention and motivate action.
High-volume third-party seller: A marketplace seller who crosses a legal threshold and triggers extra identity and contact disclosures under certain laws.
Huang Zheng: The founder associated with Pinduoduo who wrote about stepping down from the board and changing voting rights in a public shareholder letter.
INFORM Consumers Act: A United States (North America) law that requires certain online marketplaces to verify and disclose information about high-volume sellers and provide reporting tools.
Lei Chen: A senior leader of PDD Holdings shown in public filings as chairman or co-chairman and co-chief executive officer.
Minimum purchase amount: A rule that requires a cart to reach a certain total before an order can be placed or a deal can apply.
PDD Holdings: The public company group connected in reporting and filings to the Temu marketplace and to Pinduoduo.
Temu: A shopping marketplace known for very low prices, frequent promotions, and direct-from-seller offers, with a strong game-like layer.
Variable reward: A reward pattern where the timing and size of a prize change, which can increase repeated checking and continued use.
Whaleco Inc.: The Delaware, United States (North America) company named in Temu’s U.S. terms as the contracting party for users.
My Diary - Leonardo Cardillo 