Nutraceutical and Supplement Merchant Accounts

Auto-ship, subscribe-and-save and free-trial offers are common in supplements, and they are also where many disputes start. Visa and Mastercard both publish specific rules for merchants that roll a trial or introductory offer into recurring billing, and U.S. federal law sets its own baseline. The summary below is general information drawn from the sources listed at the end; your acquirer's requirements and current card-brand rules control.

Visa rules for trials and introductory offers

Visa's subscription-merchant policy (effective 18 April 2020) applies to merchants selling physical or digital goods when a free trial or introductory offer rolls into an ongoing subscription. Visa requires:

• Express consent at enrollment to an ongoing subscription with recurring payments.
• An electronic copy of the terms at enrollment (email or text), even if nothing is due that day: that the customer agreed to a subscription, the start date, the goods, the ongoing amount and billing frequency, and a simple way to cancel online.
• A reminder at least 7 days before the first recurring charge after a trial, introductory or promotional period ends, or when the price or billing period changes, with a link to cancel online.
• Receipts that show the length of the trial or promotional period, that the customer will be charged unless they cancel, the amount and date of the first and later charges, and a way to cancel.
• Easy online cancellation, regardless of how the customer signed up. Visa compares it to unsubscribing from an email list.
• A trial descriptor (for example "trial" or "free trial") in the merchant name on the first charge after the trial ends.

Visa also expanded dispute condition 13.5 (Misrepresentation) for customers who say they were not clearly told about further billing. Visa says merchants are protected if they can prove the customer expressly agreed to future charges and was notified electronically before charges resumed.

Mastercard rules for free-trial merchants

Mastercard announced standards for free-trial merchants of physical products, with a primary focus on nutraceuticals, effective April 12, 2019. J.P. Morgan's published summary lists:

• Registration in the Mastercard Registration Program, and MCC 5968 (Direct Marketing – Continuity/Subscription Merchants) for registered accounts.
• The trial period begins on the date the customer receives the product.
• Before the first charge after the trial, the customer's consent to further payments, with a notice showing the amount, the payment date, the merchant name as it will appear on the statement, and how to cancel.
• A receipt by email or text with cancellation instructions every time an authorization is requested.
• A direct link to an online cancellation process on the website where the sale happened, plus a customer service phone number.
• Written confirmation when a trial or negative-option plan is cancelled.

U.S. law: ROSCA and the FTC rule

The Restore Online Shoppers' Confidence Act (15 U.S.C. 8403) prohibits charging for goods or services sold online through a negative option feature unless the seller clearly and conspicuously discloses all material terms before collecting billing information, gets the customer's express informed consent before charging, and provides simple mechanisms to stop recurring charges.

The FTC's 2024 "click-to-cancel" amendments to the Negative Option Rule were vacated by the Eighth Circuit. In a final rule effective February 12, 2026, the FTC restored the rule's text as it stood before the 2024 amendments. ROSCA still applies, and state auto-renewal laws may add requirements. Check current law with counsel.

Descriptors and chargeback prevention for subscriptions

• Use a descriptor customers recognize: your brand name as it appears on your site. Mastercard's free-trial standards also require contact details with each transaction: the website URL for e-commerce sales, or a phone number for mail and telephone orders.
• Match every page to the checkout: the offer, price, shipping and renewal terms should read the same on ads, landing pages, checkout and emails.
• Send the confirmation, reminder and receipt emails the card brands require, and keep records showing consent and notices were sent.
• Make cancellation fast: an online cancel link, a monitored support inbox and quick refunds can cost less than a dispute.
• Watch your dispute and fraud ratios each month. Our guide to Visa's VAMP threshold explains the ratio and the 2026 limits, and What Is a Chargeback? covers the basics.
• Plan cash flow for a possible reserve. Subscription and trial programs are among the models where processors may hold back part of sales. See how rolling reserves work.

Sources: Visa: Updated Policy for Subscription Merchants Offering Free Trials or Introductory Promotions; J.P. Morgan: Mastercard Announces Revised Standards for Free Trial Merchants; 15 U.S.C. 8403 (Cornell LII); Federal Register, February 12, 2026, FR Doc. 2026-02866. This section is general information, not legal advice.