I think I found additional information that explains it.
https://en.wikipedia.org/wiki/The_Lord_of_the_Rings_Trading_Card_Game
Promotional Cards (Spring 2002 - Summer 2007)
Cards were sold in eleven card booster packs consisting of one rare, three uncommon and seven common cards. In approximately one in six packs a common was replaced by a foiled version of a random card from that set. Each set also had two sixty-three card starter decks containing two copies of a promotional face card, three random rares and sixty fixed commons/uncommons (sets 5 and 6 had sixty card starters with three alternate image rares in place of the random rares).
Based on this, it sounds like the promo cards need their own checklist, which I'm not finding already created. I was able to find the complete list of promos here:
https://lotrtcgwiki.com/wiki/set0