Tagada
Payments · Skincare4 min readUpdated October 26, 2026

Trial Offers for Skincare Brands: Rules and Conversion

What the FTC pursued in skincare trial cases, the Visa, Mastercard and Stripe trial rules, what processors accept, and offers that convert instead.

Nick Bonnassies, CMO at Tagada · checked against 10 sources

Article summary

TL;DR

Skincare trials are legal with clear terms and consent, but the category carries the FTC's best-known trial cases: "risk-free" creams for the price of shipping, followed by monthly charges. Processors remember. If you run a trial, show its length, price and next charges separately before payment, remind at least 7 days before it ends, and let customers cancel online. Many processors still refuse "free plus shipping" offers.

  • In AuraVie, "risk-free" skincare trials led to charges "of up to $97.88 per month"; refunds of $1.8 million went to 79,771 consumers.
  • In Tarr, a $4.95 trial led to about $87 a month; different site versions were shown to banks and processors; the $179 million judgment was suspended after about $6.4 million was paid.
  • Visa requires trial terms shown separately, a reminder at least 7 days before the end, and online cancellation.
  • Stripe prohibits "reduced price trials with unclear or hidden pricing".
  • Soar Payments refuses "free plus shipping fee" offers; PaymentCloud on free trials: "Most likely, no."
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This guide is part of our hub on skincare payment processing.

What the FTC pursued

CaseYearsWhat happenedSource
AuraVie (BunZai Media)2015 to 2019"Risk-free" skincare trials, then charges up to $97.88 a month; 33 defendants; $1.8 million refunded to 79,771 consumersFTC1FTC, BunZai Media Group (AuraVie) case, 2015 to 2019
Tarr2017Anti-wrinkle and supplement trials at $4.95, then about $87 a month; fake news sites; different site versions shown to banksFTC2FTC, Tarr Inc. case, November 2017
Triangle Media and others2019"RISK FREE" trials of skin creams and supplements for about $4.95, then up to $98.71; judgments of $48.1 million and $123.1 million, partly suspendedFTC3FTC, Online marketers barred from deceptive free trial offers and unauthorized billing, May 31, 2019

$97.88

Monthly charges after AuraVie's "risk-free" skincare trials

79,771

Consumers who shared $1.8 million in AuraVie refunds

$4.95

First charge in the Tarr and Triangle Media trials

$123.1 million

Largest judgment in the 2019 Triangle Media cases, partly suspended

The pattern is what processors look for: a low first charge, terms hidden or small, auto-enrollment, hard cancellation.

  1. A low first charge

    About $4.95 in the Tarr and Triangle Media trials2FTC, Tarr Inc. case, November 20173FTC, Online marketers barred from deceptive free trial offers and unauthorized billing, May 31, 2019.

  2. Terms hidden or small

    In Tarr, different site versions were shown to banks2FTC, Tarr Inc. case, November 2017.

  3. Auto-enrollment

    In AuraVie, charges up to $97.88 a month followed1FTC, BunZai Media Group (AuraVie) case, 2015 to 2019.

  4. Hard cancellation

    Visa and Mastercard require online cancellation for online orders4Visa Core Rules and Visa Product and Service Rules, edition of April 18, 2026, tables 5-20 and 5-215Mastercard, Subscription/recurring payments and negative option billing merchants: FAQs, 2022.

The rules for trials

RequirementRuleSource
Terms shown separatelyLength, price after, frequencyVisa4Visa Core Rules and Visa Product and Service Rules, edition of April 18, 2026, tables 5-20 and 5-21
Express consentTo the trial and what followsVisa4Visa Core Rules and Visa Product and Service Rules, edition of April 18, 2026, tables 5-20 and 5-21, ROSCA8Restore Online Shoppers' Confidence Act, 15 U.S.C. § 8403
ConfirmationTerms and cancellation, right after sign-upMastercard5Mastercard, Subscription/recurring payments and negative option billing merchants: FAQs, 2022
ReminderAt least 7 days before the trial endsVisa4Visa Core Rules and Visa Product and Service Rules, edition of April 18, 2026, tables 5-20 and 5-21
Mastercard post-trial reminderFor trials longer than 7 daysMastercard5Mastercard, Subscription/recurring payments and negative option billing merchants: FAQs, 2022
CancellationOnline, for online ordersVisa4Visa Core Rules and Visa Product and Service Rules, edition of April 18, 2026, tables 5-20 and 5-21, Mastercard5Mastercard, Subscription/recurring payments and negative option billing merchants: FAQs, 2022
RegistrationNegative option billing of physical products: MCC 5968, which names cosmeticsMastercard6Mastercard Security Rules and Procedures, Merchant Edition, February 11, 2025, section 9.4.10, Visa10Visa Merchant Data Standards Manual, April 2026
NoHidden pricing"Reduced price trials with unclear or hidden pricing" prohibitedStripe7Stripe, Restricted and prohibited businesses, updated September 22, 2026

Tagada follows Visa and Mastercard rules and the laws that apply to payments.

What processors publish

ProcessorPositionSource
Soar PaymentsRefuses "free plus shipping fee" offers and free trials9Soar Payments and PaymentCloud, published terms, read October 2026
PaymentCloudFree trials: "Most likely, no."9Soar Payments and PaymentCloud, published terms, read October 2026
StripeUnclear trials prohibited7Stripe, Restricted and prohibited businesses, updated September 22, 2026

A compliant trial, step by step

  1. Next to the pay button: "14-day trial of the serum for $5. Then $48 every 60 days unless you cancel. Cancel online anytime."
  2. A separate checkbox for the trial terms4Visa Core Rules and Visa Product and Service Rules, edition of April 18, 2026, tables 5-20 and 5-21.
  3. Confirmation email with terms and cancellation link5Mastercard, Subscription/recurring payments and negative option billing merchants: FAQs, 2022.
  4. Reminder at least 7 days before conversion4Visa Core Rules and Visa Product and Service Rules, edition of April 18, 2026, tables 5-20 and 5-21.
  5. One-click cancellation, confirmed by email.
  6. Brand name in the descriptor.
  7. Tell your processor before launch.

Based on Visa's trial rules, Mastercard's subscription FAQs and ROSCA. The $5 and $48 are an example.

Fig. 1A 14-day serum trial, day by day

  1. Day 0: sign-upTerms shown separately, express consent
  2. Day 0: confirmationTerms and cancellation link by email
  3. Day 7: reminderAt least 7 days before the trial ends
  4. Day 14: first charge$48, then every 60 days
  5. Anytime: cancelOnline, confirmed by email

Each step has a rule behind it.

Illustrative example. Rules: Visa Core Rules, April 2026, and Mastercard subscription FAQs, 2022.

Alternatives that convert without a trial

OfferWhy it works
Travel size or sample, paidA real first purchase, low risk
Subscribe and save on the first orderDiscount without a surprise charge
Money-back guaranteeRemoves the risk a trial removes
Routine bundle discountHigher first order
Gift with purchaseLets customers try a second product

Building the offer: the skincare sales funnel. Subscription rules: how to sell skincare on subscription.

How Tagada helps

Trials with the terms next to the pay button

  • Subscriptions with trials, billing cycles, retries and automatic recovery
  • One-page checkout where terms sit next to the pay button
  • One-click upsells and order bumps for samples and routine add-ons
  • TagadaPay underwrites each file, with enhanced review on regulated verticals

Plans are on the pricing page.

Apply for processing
Trials with the terms next to the pay button

Updated on October 26, 2026

Nick Bonnassies

CMO at Tagada

CMO at Tagada. Before Tagada, Nick built direct-to-consumer brands that generated over $115M in sales, raised over $25M in crowdfunding and sold two of them. He also works as a fractional CMO on marketing operations and AI systems.

Frequently asked questions

Are skincare free trials legal?

Yes, with clear terms before payment, express consent and a simple way to cancel, plus Visa's and Mastercard's trial rules. The FTC's cases targeted trials with hidden terms and unauthorized charges.

Why do processors refuse skincare free trials?

The category's history: AuraVie and Tarr used "risk-free" trials and hidden monthly charges. Soar Payments refuses "free plus shipping fee" offers, and PaymentCloud's answer is "Most likely, no."

What does Visa require for a free trial?

Trial terms shown separately, express consent, a reminder at least 7 days before the trial ends, and online cancellation for online orders.

What's a better offer than a skincare free trial?

A paid travel size, a subscribe-and-save first order, a money-back guarantee, or a gift with purchase. They let customers try with no surprise charge, so disputes stay low.

Sources

Checked October 26, 2026
  1. FTC, BunZai Media Group (AuraVie) case, 2015 to 2019
  2. FTC, Tarr Inc. case, November 2017
  3. FTC, Online marketers barred from deceptive free trial offers and unauthorized billing, May 31, 2019
  4. Visa Core Rules and Visa Product and Service Rules, edition of April 18, 2026, tables 5-20 and 5-21
  5. Mastercard, Subscription/recurring payments and negative option billing merchants: FAQs, 2022
  6. Mastercard Security Rules and Procedures, Merchant Edition, February 11, 2025, section 9.4.10
  7. Stripe, Restricted and prohibited businesses, updated September 22, 2026
  8. Restore Online Shoppers' Confidence Act, 15 U.S.C. § 8403
  9. Soar Payments and PaymentCloud, published terms, read October 2026
  10. Visa Merchant Data Standards Manual, April 2026

TagadaPay

Run a skincare trial your processor will accept

Tell us what you sell and how you sell it. Each application is underwritten, and approval is not guaranteed.

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  3. 03Process through TagadaPay alongside your other processors