What AB 628 Actually Means for You
No legalese. No hedging. Just the three things this law requires. and the one clock most property managers don't know is already ticking.
The 3 Things AB 628 Requires
- Working stove + refrigerator in every covered unit. These are now legally required to be in habitable condition. not just present, but functional and recall-free.
- 30-day mandatory repair/replace window. From the moment a CPSC recall notice exists for any covered appliance, you have 30 days to remediate. Period. The clock doesn't wait for you.
- Documented compliance per unit. The law creates a rebuttable presumption. you must be able to demonstrate compliance, not just claim it verbally.
The Hidden Clock Problem
Here's what most property managers don't know: "Notice" under AB 628 is triggered the moment a recall appears on CPSC.gov. not when your software notifies you, not when a tenant complains, not when you see a news article.
This is the critical distinction that can turn a manageable maintenance issue into a statutory violation with immediate damage accrual. If a Samsung stove used in your unit is recalled on Monday and you don't learn about it until Day 32… you're already in breach.
Courts may interpret the moment a CPSC recall is publicly posted as constructive notice to all landlords. meaning you are "notified" whether or not you actually saw it. The 30-day clock runs from that date. AppFolio and Buildium do not track recall serial numbers. That's your gap.
Why Manual Compliance Is Nearly Impossible at Scale
There were 376 CPSC recalls in 2025. up 13% year-over-year. Roughly 21% (about 80/year) are appliance recalls. For a 2,000-unit portfolio, that means 2–4 active recalls per year are statistically expected to affect at least one unit. CPSC posts recall alerts to their website and via email subscription. but matching those recalls against your specific serial numbers, in your specific units, on the day they publish, requires a system you likely don't have today.
AB 628 applies to leases entered into, amended, or extended on or after January 1, 2026. However, best practice. and what a plaintiff's attorney will argue. is to treat all occupied units as covered for habitability purposes. Build your compliance system for 100% of your portfolio, not just new leases.
Your Liability Exposure
Five specific ways a tenant can come after you. with real dollar figures and a real California case study that should end the "we'll deal with it when it happens" mindset.
Rent Abatement
Tenant can seek a percentage reduction of rent for each day the unit remains non-compliant after the 30-day deadline. Abatement accrues daily. retroactively.
Repair-and-Deduct (Civil Code § 1942)
After providing notice, tenant may repair the issue themselves and deduct up to one month's rent from the next payment. No court approval required.
Retaliation Damages
If any adverse action follows a tenant's complaint about recall compliance, you're exposed to actual damages plus punitive damages and mandatory attorney's fees.
Constructive Eviction
If a recalled, potentially dangerous appliance makes the unit unlivable, a tenant can claim constructive eviction. entitling them to substantial damages including relocation costs.
Tort Claims (Aggravated Cases)
In cases involving actual injury from a recalled appliance left unremediated, tort liability exposure escalates dramatically. including potential punitive damages.
A mid-size California property manager with 400 units had a Samsung refrigerator in one unit subject to a CPSC recall. The PM wasn't monitoring CPSC.gov. The tenant discovered it 45 days after publication. 15 days past the AB 628 deadline. The tenant hired an attorney, claimed rent abatement, retaliation, and violation of Civil Code § 1941.1. The PM settled before trial.
Samsung's 2016 dishwasher recall resulted in a $150M class settlement affecting 2.8 million units. This established the precedent that appliance manufacturers. and landlords who knowingly retain recalled appliances. face massive exposure. For California landlords, AB 628 codifies exactly this liability chain into statute.
The AB 628 Compliance Checklist
5 steps. Check each box as you complete it. This checklist, fully executed, is what "AB 628 compliant" actually looks like. Save this page. it is your compliance framework.
Work through all 5 steps in order. Each step builds on the previous. Check items off as you complete them. Print this page and use it as your physical compliance log. If you find a gap in any step, address it immediately. the 30-day clock doesn't care about your internal processes.
You cannot monitor what you haven't documented. Your registry is the foundation of all downstream compliance. Without serial numbers, you're flying blind.
You have a 1-hour detection window before the 30-day clock begins. Every day you miss finding a recall is a day of exposure you cannot recover.
When Day 0 hits, confusion costs time. Your 30-day clock is a sprint. every stakeholder needs to know their role before Day 0 arrives.
Contractor invoices alone are not enough. Court-admissible documentation has specific requirements. timestamped, photographic, serial-number-linked. Most property managers discover this gap too late.
The final step closes the loop. A compliance certificate per unit is your ultimate defense. it shifts the burden of proof and signals to any plaintiff's attorney that you're organized, documented, and not worth fighting.
Automate All 5 Steps with RecallProof →
RecallProof handles detection, matching, documentation, and certification automatically. so you hit the 30-day deadline on every unit, every time, without building it manually.
Automate All 5 Steps with RecallProof →5 Compliance Mistakes Property Managers Are Making Right Now
These aren't theoretical. Each of these gaps is visible in how most mid-market property managers currently operate. and each one is a direct path to AB 628 liability.
Mistake #1: Assuming Your PM Software Will Catch Recalls
AppFolio, Buildium, and other property management platforms do not track appliance serial numbers against CPSC recall databases. They're lease and maintenance management tools. not recall compliance systems. Waiting for a notification from your PM software means waiting forever.
Mistake #2: Waiting for a Tenant Complaint Before Acting
The 30-day clock starts when the recall is published on CPSC.gov. not when your tenant texts you about it. By the time a tenant raises the issue, you may already be in breach. Worse, a tenant who raises the issue is now a potential plaintiff who knows the timeline.
Mistake #3: Using Contractor Invoices as Your Only Documentation
A contractor invoice proves a repair was paid for. It does not prove the specific recalled appliance was removed, that the correct serial number was addressed, that a replacement was installed, or when exactly each step occurred. Plaintiff attorneys eat contractor-invoice-only defenses for breakfast.
Mistake #4: Monitoring by Brand or Model Without Serial Numbers
CPSC recalls are typically limited to specific serial number ranges. not all units of a brand or model. Monitoring for "Samsung refrigerator recalls" without knowing which serial numbers are in your units means you can't confirm whether your specific appliances are affected. Brand-level awareness is a starting point, not compliance.
Mistake #5: Treating AB 628 Like a Routine Maintenance Request
Normal maintenance requests have flexible timelines. AB 628 compliance has a statutory 30-day deadline with daily damage accrual from Day 31. Routing a recall remediation through your standard maintenance workflow. which may have 2–3 week response times. is not adequate. This is a compliance event, not a work order.
All 5 mistakes share the same root cause: treating AB 628 as a maintenance problem rather than a compliance system. The penalty structure of AB 628 assumes you have a system. If you don't, the law doesn't give you credit for good intentions. only for demonstrated compliance.
The AB 628 Compliance Scorecard
Rate your current compliance posture across 5 dimensions. Be honest. this is for your protection, not a performance review. Total score determines your current risk level.
% of units with documented appliance serial numbers
Can you detect a relevant recall within 1 hour of CPSC publication?
Does everyone know what to do on Day 0 of a recall event?
Can you produce court-admissible documentation for any past recall?
Can you generate a per-unit compliance certificate for each incident?
Your Path to Full AB 628 Protection
You now have the checklist. Here's what it takes to implement it. manually vs. with automated support.
If You're Building This Manually
Manually executing all 5 steps for a 500-unit portfolio requires approximately:
| Task | Manual Effort / Year | With RecallProof |
|---|---|---|
| CPSC Monitoring | 50 hrs/yr ($2,500 loaded cost) | Automated. $0 labor |
| Serial Number Matching | Hours per recall event | Instant. auto-matched |
| Tenant Notification Drafting | 30–60 min per incident | Auto-generated + logged |
| Documentation Package | 2–4 hrs per incident | Auto-generated Proof Pack |
| Compliance Certificate | Custom per-unit creation | 12-page court-admissible PDF |
| 30-Day Deadline Tracking | Manual calendar management | Automated SLA countdown |
RecallProof handles all 5 compliance steps automatically: detection, matching, documentation, certification. Your team exports the unit roster from AppFolio or Buildium once, and RecallProof takes it from there. The result is a 12-page court-admissible Proof Pack auto-generated on remediation completion. Professional tier starts at $0.75/unit/month. Less than a coffee per unit per year to eliminate your largest statutory exposure.