Can a supplement subscription keep charging me after I cancel?
No — but a 2025 court ruling changed which federal rule actually stops it.
No. Charging you for a supplement subscription after you've properly cancelled is illegal, full stop. That protection comes from the Restore Online Shoppers' Confidence Act (ROSCA), a federal law that's been in force since 2010 and wasn't touched by the recent court fight over the FTC's newer "Click-to-Cancel" rule. What changed in 2025 isn't whether post-cancellation charges are legal — they're not — it's how easy the law requires cancellation to be in the first place.
What actually happened to "Click-to-Cancel"
In 2024 the FTC finalized amendments to its Negative Option Rule, commonly called Click-to-Cancel, which would have required sellers to make cancelling a subscription as simple as signing up for one. It was set to take full effect in July 2025. Days before that deadline, the Eighth Circuit Court of Appeals vacated the entire rule in Custom Communications, Inc. v. FTC, ruling that the FTC skipped a required procedural step (a preliminary economic-impact analysis) before finalizing it — a process defect, not a ruling that charging people after cancellation is fine.
With the amended rule gone, the original 1973 Negative Option Rule is what's left standing at the federal rulemaking level, and it's narrower — it mainly covers prenotification plans (like book-of-the-month clubs), not the broad "make cancellation as easy as sign-up" standard the 2024 version added.
What still protects you — ROSCA
| Law | Status | What it does |
|---|---|---|
| ROSCA | Fully in force | Bans charging you for a recurring subscription without clear disclosure, without your consent, and after a proper cancellation |
| 2024 Click-to-Cancel amendments | Vacated by Eighth Circuit, July 2025 | Would have required cancellation to be exactly as easy as sign-up |
| Original 1973 Negative Option Rule | In force | Narrower disclosure rules, mainly for prenotification plans |
ROSCA is a separate statute from the Negative Option Rule, and it wasn't part of the case that was vacated. It still requires sellers to clearly disclose the subscription's material terms, get your consent before billing you, and provide a way to stop the charges — and it's still fully enforceable by the FTC and by consumers through related state laws.
What this means in practice for a supplement subscription
- The seller can still legally make cancellation more annoying than it should be (multiple steps, a required phone call) now that Click-to-Cancel's "as easy as sign-up" standard isn't federally mandated.
- But once you've actually completed whatever cancellation process the company requires, any charge billed after that point is unlawful under ROSCA, not just a policy violation.
- Many states have their own automatic-renewal laws layered on top of federal protections, so a subscription might also violate state law depending on where you live.
What to do if you're charged after cancelling
- Gather proof of the cancellation — confirmation email, order-portal screenshot, chat transcript, or a call reference number — with the date attached.
- Contact the company in writing, cite the cancellation date, and ask for an immediate refund of the post-cancellation charge.
- If the company doesn't refund it, dispute the specific charge with your card issuer as unauthorized, attaching your cancellation proof.
- File a complaint with the FTC at ReportFraud.ftc.gov — even without the amended rule, ROSCA violations are still something the FTC investigates and pursues.
Is the FTC's Click-to-Cancel rule still in effect? No. The 2024 amended Negative Option Rule, known as Click-to-Cancel, was vacated in its entirety by the Eighth Circuit Court of Appeals in July 2025 over a procedural rulemaking defect. The prior, narrower 1973 Negative Option Rule remains in effect, and ROSCA's ban on charging consumers after cancellation still applies.
What should I do if a supplement company keeps charging me after cancellation? Keep proof of your cancellation request (email, confirmation number, screenshot), dispute the post-cancellation charge directly with the company in writing, and if it isn't refunded, file a chargeback with your card issuer citing the cancellation date and evidence.
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