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Visa and Mastercard Free-Trial Rules for Supplement Brands

Supplement payments guide

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.

Card network rules checked October 30, 2026 10 minute read
Background

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.

Side by side

Visa vs. Mastercard free-trial rules at a glance

Most of the requirements overlap. The biggest difference is what happens when the trial ends.

RequirementVisaMastercard (physical products)
CheckoutVisaTrial length, amounts and dates, and that the customer will be charged unless they cancel, clearly visible on the checkout screenMastercardInitial charge, trial length, and later price and frequency, shown with the request for card details. No links or scroll boxes
ConsentVisaExpress consent through a click-to-accept button at checkoutMastercardAffirmative acceptance at checkout
ConfirmationVisaReceipt or written confirmation straight after signup, sent electronicallyMastercardOrder confirmation by email or other electronic method, with cancellation instructions
When the trial endsVisaNotice at least 7 days before the first charge, with the amount, date and an online cancel linkMastercardExplicit consent from the customer before the first full-price charge
Every chargeVisaReceipts and notices sent electronically if the customer signed up onlineMastercardElectronic receipt with cancellation instructions
CancellationVisaEasy online cancellationMastercardOnline or electronic cancellation, plus written confirmation of the cancellation
RegistrationVisaNo separate registration in the public rulesMastercardBank must register you and use MCC 5968 for these transactions
Sources: Visa Core Rules, Oct. 24, 2026 edition · Mastercard Transaction Processing Rules, June 9, 2026 · Mastercard Security Rules, Feb. 11, 2025
Visa

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

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.
The rule that catches supplement brands

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.

Putting it together

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.

Example checkout disclosure Meets both networks
You'll pay $4.95 today for a 14-day trial of Daily Greens. If you don't cancel by May 15, you'll be charged $59.00 on May 15 and every 30 days after that until you cancel. Cancel any time online at yourbrand.com/cancel.
Next to the card fieldsNot behind a link, a tooltip or a scroll box.
Unchecked boxThe customer has to tick it. Pre-checked boxes don't count as consent.
Real dates and amounts"Billed monthly" is weaker than a date and a price.
  1. Day 0

    Checkout and confirmation

    Terms at checkout, an unchecked box, then an immediate confirmation email with the terms and a cancel link.

  2. 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.

  3. 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.

  4. After consent

    First full-price charge

    Charge under the same merchant ID and name used for the trial. Send a receipt with cancellation instructions.

  5. Every month

    Receipt after each charge

    An email or text receipt with the amount, the reason for the charge and how to cancel.

  6. 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.

Red flags

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.
The legal layer

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.

Merchant questions

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.

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