Visa and Mastercard free-trial rules for supplement brands
A "just pay shipping" offer can still work for a supplement brand, but only if checkout, emails and billing follow the card networks' rules. Here's what Visa and Mastercard require, where they differ, and the steps that catch most brands out.
Why card networks police supplement free trials
A free or low-cost trial that rolls into a monthly subscription is called a negative option offer: the customer keeps paying unless they act to stop it. When the terms are unclear, customers dispute the charges they didn't expect, and those disputes land on the bank that processes for you.
Supplements are squarely in the networks' sights. Mastercard's own rule defining negative option billing uses cosmetics, health-care products and vitamins as its examples. And under Visa's rules, a cardholder who bought through a trial and wasn't clearly told about later charges can dispute them as misrepresentation.
That's why a nutraceutical merchant account application gets extra questions about trials and autoship. The rules below are what underwriters check your checkout against.
Visa vs. Mastercard free-trial rules at a glance
Most of the requirements overlap. The biggest difference is what happens when the trial ends.
Visa's free-trial rules, step by step
Visa tightened its trial rules in April 2020, and they apply to physical and digital products alike. The current Visa Core Rules ask a negative option merchant to do four things.
- Disclose before the sale. Show your business name, what you're selling, how long the trial lasts, the amount and date of the first charge (even if it's $0) and of later charges, the last four digits of the card, your cancellation policy, and a clear statement that the customer will be charged unless they cancel.
- Get express consent. For an online sale, that means a click-to-accept button on the checkout screen.
- Confirm straight away. Send a receipt or written confirmation after signup. If the customer signed up online, every receipt and notice must be electronic.
- Warn before the trial ends. At least 7 days before charging, send a notice when a trial, introductory offer or promotional price is ending, or when your terms change. Emails must link to a page where the customer can cancel online.
The 7-day notice also protects you. To fight a misrepresentation dispute on a trial sale, Visa's rules say you need to prove two things: the customer expressly agreed to future charges at signup, and you notified them at least 7 days before the charge.
Mastercard's rules for physical-product trials
Mastercard has two layers. Its subscription rules cover every recurring plan, and its negative option rules add extra steps when the trial is for a physical product such as a supplement.
Subscription rules (all autoship plans)
- Terms next to the card fields. Show the price and billing frequency, plus the initial charge and trial length for a trial, on the payment and order summary pages. A link, an expandable box or text below the fold doesn't count.
- Affirmative acceptance before the order completes, then an immediate confirmation by email or another electronic method, with instructions for canceling.
- Online cancellation, or clear cancellation instructions that are easy to find online, such as a "Cancel Subscription" link.
- A renewal reminder for long billing cycles. For plans billed every six months or less often, send a reminder 7 to 30 days before billing, separate from marketing emails.
For physical-product trials, Mastercard says that after the trial ends, you must get the customer's explicit consent before the first full-price charge. Before asking, you have to tell them:
- The date the subscription starts
- The amount and the payment date
- Your business name as it will appear on their statement
- How to cancel
Extra rules for physical-product trials
- A receipt after every charge, by email or text, with instructions for canceling. If you send a receipt for a declined charge, say why it was declined.
- Seven days' written notice before you change billing terms, and written confirmation within seven days when a subscription is canceled.
- The same merchant ID and business name on every charge after the trial as on the first one, so customers recognize it.
- Registration. Mastercard's Security Rules require your bank to register you as a negative option merchant and to run these transactions under MCC 5968, the code for continuity and subscription merchants.
Mastercard's subscription FAQ adds that the rules still apply if you aren't using MCC 5968, and that they apply offer by offer. An occasional discounted first order doesn't turn your whole store into a negative option merchant.
What a compliant supplement trial looks like
Building one flow that meets both networks' rules is simpler than running two. Here's the sequence for a 14-day trial at $4.95 shipping that becomes $59 a month.
- Day 0
Checkout and confirmation
Terms at checkout, an unchecked box, then an immediate confirmation email with the terms and a cancel link.
- Day 7
Trial-ending notice
At least 7 days before billing, email the amount, the charge date and a link to cancel online. This is Visa's requirement and your best defense against disputes.
- Day 14
Trial ends: ask for consent
For Mastercard, send the subscription start date, amount, payment date, statement name and how to cancel, and record the customer's yes before you charge.
- After consent
First full-price charge
Charge under the same merchant ID and name used for the trial. Send a receipt with cancellation instructions.
- Every month
Receipt after each charge
An email or text receipt with the amount, the reason for the charge and how to cancel.
- On cancel
Stop billing and confirm in writing
Cancel online with no phone call required, and send written confirmation within seven days.
One thing to settle with your processor: whether a customer who doesn't respond to the consent request should be billed. Under Mastercard's wording, no confirmation means no first charge on a Mastercard card. The simplest approach is to ask every trial customer to opt in, whatever card they used.
Common free-trial mistakes that cost supplement brands their accounts
These are the problems we see most often when we review a supplement trial before an application.
- Terms in the footer"Just pay shipping" in big type, with the $79 charge in small print or behind a link.
- A pre-checked boxConsent has to be an action the customer takes.
- Reminder buried in marketingA trial notice inside a promo email is easy to miss and hard to prove later.
- Phone-only cancellationBoth networks expect customers to be able to cancel online.
- A different name on the statementA charge customers don't recognize becomes a dispute.
- No proofIf you can't show the consent click and the notice email, you'll lose the dispute even when you did both.
U.S. law sits on top of the card rules
Card network rules are contract terms between you, your bank and the networks. Federal and state laws apply as well, and they can be stricter.
- ROSCA requires online negative option sellers to clearly disclose material terms before taking billing information, get express informed consent, and provide a simple way to stop recurring charges.
- The FTC's "click to cancel" rule was vacated by the Eighth Circuit in 2025. The FTC reopened the rulemaking in March 2026, so new federal requirements may follow.
- State automatic renewal laws, such as California's, add their own disclosure, consent and cancellation rules for customers in those states.
This is a summary of public card network rules, not legal advice. Have a lawyer review your offer, and confirm the current rules with your processor.
Supplement free-trial FAQs
Does a "just pay shipping" offer count as a free trial?
Yes. Visa's rules cover trials, introductory offers and promotional periods, and Mastercard's cover samples that are free or sold at a nominal price. If a low first payment rolls into a subscription, treat it as a trial.
Do these rules apply to regular autoship with no trial?
Partly. Mastercard's subscription rules apply to all recurring plans: terms at checkout, affirmative acceptance, a confirmation email and online cancellation. Visa requires an online cancellation option and notice before charging when your terms change. The trial-specific steps only apply when there's a trial or introductory price.
Can a supplement brand still run free trials?
Yes, but not every bank will accept them, and those that do will look closely at your checkout, emails and dispute history. Expect questions about trials during underwriting for a high-risk merchant account.
Do I need a separate merchant ID for trial offers?
Often, yes. Mastercard requires your bank to register physical-product trial merchants and process those charges under MCC 5968, so trial offers usually run on their own merchant ID. Mastercard also requires the same merchant ID and name on every charge after the trial.
What if my trial is shorter than seven days?
You can't send a 7-day reminder before a 5-day trial ends. Visa's guidance is to include the trial end date and a cancellation link in the signup confirmation instead. Mastercard's consent step still applies before the first full-price charge on a physical product.
Running a trial or autoship? Get it reviewed before an underwriter does.
Send us your checkout page, confirmation email and reminder email. A DMS specialist will check them against Visa and Mastercard rules and tell you what to fix before you apply.