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.
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.
| 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.
Use Kibbo's Health & Supplements tools to draft a ROSCA-backed refund request and chargeback letter.
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