It is quite common for cars to be painted prior to being sold from new. The dealership I used to work for even had it's own Panel Shop.
It's a little hard to tell by the pictures but I'm kind of thinking that it's factory paint flaking as the rubber mould between the body and the mould is not flaking and 99% of the time that would get painted with the mould if it was touched up. It still has the texture as you can tell by the gloss variation. If it's straight from factory then that mould is painted separately which is why it's not flaking too.
It kind of looks like the base coat is separating from the plastic not paint flaking off the original paint which is what you would see if it had been touched up. The flares come painted from factory when you order new ones so it's not like they have bought new ones and got them painted either.
It's not unusual for one car in the assembly line to have a failure like this. Most plastic adhesion promoters are transparent to so they may have forgotten to paint a couple with this prior to putting the colour down.
Cheers Mick.