A greens powder shows up every 28 days. The tub lasts 30 servings. Within four months there are two unopened tubs behind the one you’re using, and the charge has become part of the background noise on your card statement.
Most people in this situation believe two things. The first is that they’ll cancel soon. The second is that if cancelling turns out to be hard, a federal rule now requires the company to let them quit the same way they signed up.
The second belief is wrong, and it matters. The Federal Trade Commission announced a “Click-to-Cancel” rule in October 2024. A federal court vacated it. In March 2026 the Commission opened a fresh rulemaking that asks, among other options, whether to adopt provisions of the rule that no longer exists.
So the honest answer to “what protects me right now” is messier than a headline. Real protections exist. They just aren’t the ones most people think they are.
Click-to-cancel is not in force, and the FTC says so itself
On March 11, 2026, the Federal Trade Commission announced an Advance Notice of Proposed Rulemaking on its Rule Concerning the Use of Prenotification Negative Option Plans, known as the Negative Option Rule. An advance notice is the earliest formal step in federal rulemaking. It isn’t a proposed rule. It’s the agency asking the public what the problem is and what, if anything, it should do about it.
The FTC’s own notice treats the 2024 rule as dead. Among the options it lists for addressing unlawful practices is “adopting provisions of the vacated 2024 Rule or some other provisions.” A rule the agency describes as vacated is a rule that is not protecting anyone today.
There’s a second piece of evidence for that, and it’s quieter. The FTC’s legal library page for the Negative Option Rule lists a Federal Register notice dated February 12, 2026, revising the Negative Option Rule, withdrawing the CARS Rule and removing the Non-Compete Rule to conform those rules to federal court decisions. The electronic Code of Federal Regulations shows the current text of the rule sourced to that same February 2026 notice. The agency cleaned its own rulebook to match what the courts had done.
The ANPRM asks four things. How businesses market negative option programs and how those programs work. Which practices stop people from understanding terms, enroll them without informed consent, or deter them from cancelling, and how widespread those practices are. How to address unlawful practices, with options including keeping the current rule, adopting provisions of the vacated 2024 rule, or non-regulatory approaches such as consumer and business education, along with the costs and benefits of each. And what market studies, economic data or other empirical evidence exist.
The Commission did not describe the problem as solved. It said it continues to receive thousands of complaints each year, more than 100,000 complaints in the past five years, about negative options and related practices. Christopher Mufarrige, director of the FTC’s Bureau of Consumer Protection, said negative option subscriptions “continue to be plagued by difficult cancellation processes” and other obstacles.
The comment period runs 30 days after Federal Register publication. The notice itself was dated March 13, 2026, with a public comment docket on Regulations.gov. Where this ends up is genuinely unsettled, and anyone who tells you otherwise is guessing.
What the rule that is in force covers
Here is the part almost nobody knows. The Negative Option Rule that currently sits in the Code of Federal Regulations, at 16 CFR Part 425, was built for a business model your grandparents would recognize.
Read the regulation and it describes a “prenotification” plan: a seller periodically mails subscribers an announcement naming a product, and subscribers receive it and get billed unless they tell the seller not to send it by a set date. That’s the record club and the book-of-the-month club. The rule makes it an unfair or deceptive practice for a seller using such a plan to skip its requirements, which include disclosing the plan’s material terms clearly and conspicuously in promotional material, disclosing any minimum purchase obligation and the right to cancel, giving subscribers at least 10 days to mail back the form, shipping introductory merchandise within four weeks, and ending a membership when a subscriber asks in writing.
Those are real obligations. They were also written for mail. A modern wellness subscription usually doesn’t send you an announcement you can decline. It charges your card on a schedule and ships automatically.
That mismatch is why the FTC is asking questions. Its own rule page frames the goal of any amendment as helping consumers avoid recurring payments they never meant to make and cancel them without unwarranted obstacles. If the rule in force already did that for modern subscriptions, there would be nothing to ask.
What still applies no matter how the rulemaking ends
Rules come and go. Statutes are harder to move, and two of them cover this ground right now.
The FTC act. Section 5(a), at 15 U.S.C. 45(a)(1), makes unfair or deceptive acts or practices in or affecting commerce unlawful. The FTC’s own description of its enforcement authority explains how each half works. A practice is deceptive when it involves a material representation, omission or practice likely to mislead a consumer acting reasonably in the circumstances. A practice is unfair, under 15 U.S.C. 45(n), when it causes or is likely to cause substantial injury to consumers that they can’t reasonably avoid and that isn’t outweighed by benefits to consumers or competition. The remedies include administrative cease and desist orders, civil penalties, injunctions in federal court under Section 13(b), and consumer redress under Section 19. Hiding a renewal term or burying a cancellation path doesn’t become legal because a rule was vacated.
ROSCA. The Restore Online Shoppers’ Confidence Act, at 15 U.S.C. 8401 through 8405, is the sleeper here. Section 8403 says a seller may not charge a consumer for goods or services sold online through a negative option feature unless it does three things: clearly and conspicuously discloses all material terms of the transaction before obtaining the consumer’s billing information, obtains the consumer’s express informed consent before charging the account, and provides simple mechanisms for the consumer to stop recurring charges. That is a statute, not a rule, and it was not vacated. The FTC’s page on the Act also covers a separate piece aimed at post-transaction third-party sellers, which may not charge your account unless they disclosed all material terms, got your express informed consent, and obtained the account number from you directly.
Read that list of three again. Clear disclosure before you hand over a card. Express informed consent. A simple way to stop the charges. The substance of what people think they lost is partly written into federal law already.
Your state may add more. The FTC’s consumer advice tells people with subscription cancellation problems or unauthorized charges to report both to the FTC, at ReportFraud.ftc.gov, and to their state attorney general. That office is the right place to ask what your state requires of automatic renewals, because the answer varies and this article can’t give you a reliable national summary of it.
How a wellness subscription is built to keep you
Set the law aside for a minute. Most money lost to subscriptions is lost to design, not to lawbreaking.
The FTC describes a negative option simply: you get billed automatically for something because you didn’t specifically say not to bill you. That inversion is the engine. Everything else is engineering around it.
The trial that needs a card. A free trial that requires card details isn’t really free if the charge lands automatically when the trial ends. The FTC’s consumer guidance makes the practical point that paying shipping or a handling fee means the offer wasn’t free to begin with, and warns about pre-checked boxes that authorize future charges.
The quantity that doesn’t match the cycle. A 30-count bottle on a 28-day shipping cycle builds a surplus. A 60-serving tub on a monthly cycle does it faster. Nobody has to deceive you. The arithmetic does the work.
Friction at the exit. Behavioral scientists have a name for this. In a 2025 paper in the journal Addiction, researcher Philip Newall lays out a taxonomy of deceptive design in online gambling platforms and uses “sludge” for detrimental friction, the deliberate difficulty added to processes a business would rather you abandoned, such as withdrawing money. The broader term in that literature is dark patterns, meaning interface design that steers people against their own interest. A cancel button that leads to four screens of retention offers is sludge by any name.
Health products are not exempt from this. A 2024 review in the German public health journal Bundesgesundheitsblatt surveyed manipulative design strategies in digital health applications and found that developers of commercial, non-approved health apps often deploy them, intentionally or not, to push users toward particular decisions. The authors argue for more transparency and closer regulatory attention. Their point generalizes: a product being about health does not make its checkout flow honest.
There is a safety angle too, and it’s easy to miss when the charge is the thing annoying you. A subscription delivers a product repeatedly with no clinician anywhere in the loop. The National Institutes of Health Office of Dietary Supplements advises telling every provider you see, including your dentist and pharmacist, about every supplement you take, with the dose and how often, and disclosing them well before any surgery, because some raise bleeding risk or change how you respond to anesthesia. New symptoms after a shipment arrives deserve the same response as any other reaction. The National Center for Complementary and Integrative Health tells people to stop the product, call their health care provider, and think about contacting the manufacturer too. Serious problems can also go to the federal government, through the Safety Reporting Portal run by the US Department of Health and Human Services.
Auditing your own recurring charges
The first step is finding out what you’re paying. This is a version that takes about twenty minutes.
- Pull three months of statements, not one. Quarterly and annual renewals hide from a single-month review, and annual charges are the expensive ones.
- Include every account. Primary card, backup card, the debit card you used once for a trial, and any payment app. Trials often land on whichever card was in the browser.
- Write one line per charge: merchant name, amount, how often, the next expected date, and what it’s for.
- Translate the processor names. A charge from a name you don’t recognize is usually a billing company, not a scam. Search the exact string from the statement before you dispute it.
- Add the column your bank won’t. Next to each line, write the last date you used or consumed the thing. That column, not the amount, is what makes decisions obvious.
- Multiply every monthly charge by twelve. Then total the page. The annual number is the one that changes behavior.
- Mark each line keep, pause or cancel. Many wellness subscriptions let you push a shipment out by weeks. If you have a surplus sitting at home, pausing is the honest move and it costs nothing.
Cancelling so it stops
Follow the company’s stated cancellation instructions first, and keep a record of it. The FTC advises saving your cancellation request and any conversations, including notes, and then watching for further charges afterward. That record is what makes everything below work.
If charges keep coming, you have two separate backstops, and they work differently.
Your bank, for payments pulled from your account. The Consumer Financial Protection Bureau lays out the sequence. Call the company and tell them you’re withdrawing permission for automatic payments, then follow up in writing or by email. Call your bank or credit union, tell them you revoked the company’s authorization, and follow up in writing there too; many banks have an online form. If your bank recommends it, consider a stop payment order, which instructs the bank not to pay a specified company from your account. Banks generally charge a fee for one. Then watch your statements and report any payment you didn’t allow right away, because federal law lets you dispute unauthorized transfers and recover the money if you notify your bank in time.
One trap in that sequence: the CFPB is explicit that stopping automatic payments does not cancel what you owe or end the underlying contract. If you want the service to end, you have to cancel the service, not just the payment.
Your card issuer, for charges you shouldn’t have been billed. The FTC recommends disputing an improper charge with your credit or debit card issuer, a chargeback, and following up in writing to the issuer’s billing disputes address, ideally by certified mail with a return receipt.
The credit card version of this has hard deadlines worth memorizing. Under the Fair Credit Billing Act, as the FTC describes it, you must dispute in writing within 60 days of the first statement that shows the charge, and the letter goes to the billing errors address rather than the payment address. The issuer must acknowledge your dispute within 30 days and resolve it within two billing cycles, and no more than 90 days. You don’t have to pay the disputed amount while it’s investigated, though you do owe the rest of the bill. Miss the 60-day window and you may be outside the law’s protection entirely.
Debit cards are weaker. The FTC says debit protections differ from credit protections and that you may not get a refund for a product that never arrived or arrived wrong. Some issuers voluntarily offer more. That difference is a practical argument for putting any trial you’re unsure about on a credit card.
One more rule people don’t know they have. If a company ships you something you never ordered and then bills you, the FTC’s position is that you don’t have to pay for it or return it. Goods you didn’t order are yours to keep.
When a subscription really is the cheaper option
This article would be dishonest if it treated every recurring charge as a trap. Some are the better deal, and the conditions are specific.
A subscription makes sense when all of these are true. You would buy the product at that interval anyway, at that quantity. The per-unit price is genuinely lower than the one-time price, which you’ve confirmed by doing the arithmetic rather than trusting the badge on the page; that calculation has its own article in this library. You can pause or skip a shipment yourself, without a phone call. And cancellation is self-serve, which you verified before enrolling by finding the cancel path, not after.
Fail any one of those and you’re buying convenience at a premium, which is a legitimate choice as long as you know that’s what you’re doing.
The deeper question is whether the product earns a standing order at all. A subscription turns a single decision into an indefinite one and removes the moment where you’d otherwise ask whether it’s working. Deciding whether a supplement is worth paying for in the first place is covered separately here, and that decision should come before the pricing one, not after.
What to rely on while the rules are unsettled
The regulatory floor may rise. The FTC’s rulemaking could end with amendments that make cancellation genuinely simple, or with education campaigns and no new rule at all. The comment docket will take months to work through, and nothing changes for consumers until it does.
In the meantime, the protections you can count on are the ones you build. A calendar reminder set for two days before a trial converts. A written record of every cancellation request. A cancel path you located before you enrolled instead of after. And the 60-day clock on a credit card billing dispute, which is the hardest deadline in this entire subject and the easiest one to blow.
If you only act on one sentence here: before your next trial sign-up, find the cancellation page first. If you can’t find it in two minutes, that’s your answer.
Keep exploring: health purchases, wellness lab panel cost, organic price premium, supplement cost per serving and should I take a supplement.
Sources
- Federal Trade Commission. “FTC Seeks Public Comment in Response to Advance Notice of Proposed Rulemaking Regarding Negative Option Marketing Practices.” ftc.gov
- Federal Trade Commission. “Negative Option Rule.” ftc.gov
- Electronic Code of Federal Regulations. “16 CFR Part 425, Rule Concerning the Use of Prenotification Negative Option Plans.” ecfr.gov
- Federal Trade Commission. “A Brief Overview of the Federal Trade Commission's Investigative, Law Enforcement, and Rulemaking Authority.” ftc.gov
- Federal Trade Commission. “Restore Online Shoppers' Confidence Act.” ftc.gov
- U.S. Government Publishing Office. “15 U.S.C. 8403, Negative option marketing on the Internet.” govinfo.gov
- Federal Trade Commission. “Getting In and Out of Free Trials, Auto-Renewals, and Negative Option Subscriptions.” consumer.ftc.gov
- Federal Trade Commission. “What To Do if You're Billed for Things You Never Got, or You Get Unordered Products.” consumer.ftc.gov
- Consumer Financial Protection Bureau. “How do I stop automatic payments from my bank account?.” consumerfinance.gov
- National Institutes of Health, Office of Dietary Supplements. “Dietary Supplements: What You Need to Know.” ods.od.nih.gov
- National Center for Complementary and Integrative Health. “Using Dietary Supplements Wisely.” nccih.nih.gov
- PubMed. “Newall P. "Sludge, dark patterns and dark nudges: A taxonomy of online gambling platforms' deceptive design features." Addiction, 2025. PubMed. DOI: 10.1111/add.70085.” doi.org
- PubMed. “Mildner T, et al. "Dark patterns: manipulative design strategies in digital health applications." Bundesgesundheitsblatt Gesundheitsforschung Gesundheitsschutz, 2024. PubMed. DOI: 10.1007/s00103-024-03840-6.” doi.org