Payments · Supplements4 min readUpdated October 26, 2026

Trial Offers for Supplement Brands: Rules and Conversion

The Visa, Mastercard, Stripe and ROSCA rules for supplement trial offers, what the FTC has pursued, a compliant setup, and alternatives that convert.

Nick Bonnassies, CMO at Tagada · checked against 9 sources

Article summary

TL;DR

Trials are legal, but they're the offer processors and regulators watch most. A compliant supplement trial shows its length, price and next charges separately before payment, gets express consent, confirms by email, reminds the customer at least 7 days before it ends, and lets them cancel online. Stripe prohibits trials with unclear or hidden pricing, and Mastercard requires registration for negative option billing of physical products.

Visa requires trial terms shown "separately from the general purchase terms", a reminder at least 7 days before the trial ends, and online cancellation.
Mastercard requires a post-trial reminder only for trials longer than 7 days, and registration with MCC 5968 for negative option billing of physical products.
Stripe prohibits "reduced price trials with unclear or hidden pricing".
In 2019 the FTC barred operators who sold "RISK FREE" trials of supplements and skin creams for about $4.95, then charged up to $98.71.
The FTC's click-to-cancel rule was vacated in 2025; ROSCA still applies.

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This guide is part of our hub on nutraceutical payment processing.

The rules for trials

Requirement	Rule	Source
Trial terms shown separately	Length, price after the trial, frequency	Visa1
Express consent	To the trial and what follows	Visa1, ROSCA5
Confirmation	Terms and how to cancel, right after sign-up	Mastercard2
Reminder before the trial ends	At least 7 days before	Visa1
Mastercard post-trial reminder	Only for trials longer than 7 days	Mastercard2
Online cancellation	For online orders	Visa1, Mastercard2
Registration and MCC	Negative option billing of physical products: register, MCC 5968	Mastercard3
NoHidden pricing	"Reduced price trials with unclear or hidden pricing" prohibited	Stripe4
California	Express consent, online cancellation, annual reminder	§ 176026

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

What the FTC has pursued

Example

Operators advertised "RISK FREE" trials of skin creams, e-cigarettes and dietary supplements for about the cost of shipping, typically $4.95. Customers were then charged up to $98.71 and enrolled in ongoing plans without consent. The FTC's 2019 orders barred the conduct, with judgments of $48.1 million and $123.1 million, partly suspended7.

$4.95

Typical "RISK FREE" trial price, about the cost of shipping

$98.71

What customers were then charged, at most

$48.1M

One of the FTC's 2019 judgments, partly suspended

$123.1M

The other 2019 judgment, partly suspended

The FTC's first ROSCA case, in 2014, also involved supplements sold through a "free trial" with undisclosed costs8. The FTC's click-to-cancel rule was vacated in 2025; ROSCA still applies9 5.

A compliant trial, step by step

Next to the pay button: "14-day trial for $4.95. Then $49 every 30 days unless you cancel. Cancel online anytime."
A separate checkbox for the trial terms, not buried in general terms1.
Confirmation email with the terms and the cancellation link2.
Reminder email at least 7 days before the trial converts1; with a 14-day trial, that's day 7 or earlier.
One-click cancellation in the account, confirmed by email1 2.
A descriptor with your brand name, so the first full charge is recognized.
Tell your processor before launching the trial; it may need a new review.

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

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

Day 0Separate consent, confirmation email with the cancel link
Day 7Reminder, at least 7 days before conversion (Visa)
Day 14First full charge, brand name in the descriptor
Any dayOne-click cancellation online

The reminder is the step most trials skip.

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

Watch out

A "free" trial that charges shipping and rolls into auto-ship is exactly what Stripe prohibits when the pricing is unclear4. Many high-risk processors refuse "free + shipping" offers outright.

Alternatives that convert without a trial

Offer	Why it works	Risk
Subscribe and save on the first order	Discount without a later surprise charge	Low, with clear terms
Money-back guarantee	Removes the risk the trial was meant to remove	Low; honor it fast
Small sample size, paid	Real first purchase	Low
Bundle discount (3 for 2)	Higher first order	Low
Discounted first month, clearly shown	Trial-like, without "free"	Medium; terms must be clear4

Subscribe and save
A discount on the first order, without a later surprise charge.
Money-back guarantee
Removes the risk the trial was meant to remove. Honor it fast.
Paid sample
A small size, and a real first purchase.
Bundle discount
3 for 2, for a higher first order.
Discounted first month
Trial-like, without "free". The terms must be clear.

Building these offers: the supplement sales funnel. Subscription rules in general: how to sell supplements 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 trial terms sit next to the pay button
One-click upsells and order bumps for offers that don't need a trial
TagadaPay lists "Supplements / nutra" among its industries; each file is underwritten, 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 free trials allowed for supplements?

Yes, if the terms are clear and the customer consents: ROSCA, Visa's trial rules and Mastercard's apply. Stripe prohibits trials with unclear or hidden pricing, and many processors refuse "free + shipping" offers.

What does Visa require for free trials?

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

Does Mastercard require a reminder after a free trial?

Only for trials longer than 7 days, per Mastercard's FAQ. It also requires a confirmation with cancellation instructions, and registration with MCC 5968 for negative option billing of physical products.

What's a good alternative to a supplement free trial?

A clear subscribe-and-save first order, a money-back guarantee, or a paid sample size. They remove the buyer's risk without a surprise charge, so disputes stay low.

Sources

Checked October 26, 2026

TagadaPay

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