The low-energy scattering of two charged particles is analyzed using a renormalization group approach based on dimensional regularization with power-divergence subtraction. A nontrivial solution with a marginally unstable direction is found, corresponding to a system with a bound state at zero energy. For purely energy-dependent perturbations around this solution, the power counting agrees with that from Wilsonian methods. These terms in the effective potential are in direct correspondence with the the terms in the Coulomb-distorted effective-range expansion. We also study perturbations that depend on off-shell momenta as well as energy, and we show that these affect only the off-shell form of the scattering matrix. These terms are of higher order than the corresponding energy-dependent ones and so terms in the potential that depend only on the off-shell momenta do not have definite orders in power counting. © 2008 The American Physical Society.