RecallProof
California AB 628 Compliance Guide 2026 Edition
California Property Managers Effective Jan 1, 2026

The AB 628 Property Manager's
Compliance Playbook

The 30-Day Deadline Is Live. Here's Exactly What California Landlords Must Do Now to Stay Protected. Before a Tenant Lawsuit Finds Them First.

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376
CPSC Recalls in 2025
30
Day Mandatory Deadline
$65k
Avg. Non-Compliance Cost
CRITICAL: The 30-day compliance clock may already be running on appliances in your portfolio. even if you've never seen the recall notice. AB 628 counts from the day it appears on CPSC.gov, not the day you find out.

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.

California Civil Code § 1941.1. Effective January 1, 2026

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.

What "Notice" Actually Means Under AB 628

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.

376
Total CPSC recalls in 2025 (up 13% YoY)
~80
Appliance recalls/year (21% of all CPSC)
$2,500
Annual labor cost of manual CPSC monitoring
Scope Clarification

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.

1

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.

Daily accrual
2

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.

Up to 1 month rent
3

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.

$2,000+/act + fees
4

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.

Substantial damages
5

Tort Claims (Aggravated Cases)

In cases involving actual injury from a recalled appliance left unremediated, tort liability exposure escalates dramatically. including potential punitive damages.

Potentially unlimited
Real-World Case Study
The $65,000 Lesson: Why "We'll Deal With It Later" Is Catastrophically Expensive

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.

$50k
Settlement amount
$15k
Legal fees (defense)
$65k
Total loss
1
Unit involved
"The 30-day clock may already be ticking on appliances in your portfolio right now. and you may not know it yet."
AB 628 Compliance Reality Check
Industry Reference: Samsung $150M Settlement

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.

How to Use This Checklist

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.

1
Build Your Appliance Registry

You cannot monitor what you haven't documented. Your registry is the foundation of all downstream compliance. Without serial numbers, you're flying blind.

Target: ≥85% serial number coverage across your portfolio
2
Activate CPSC Monitoring

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.

Goal: Know about a relevant recall within 1 hour of CPSC publication
3
Create Your 30-Day Response Protocol

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.

Goal: Zero confusion on Day 0. every stakeholder knows their role
4
Build Your Documentation System

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.

Goal: A document package that could win in court. every incident
5
Certify Compliance Per Unit

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.

Goal: 12-page court-admissible documentation package per remediated unit

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.

Fix: Establish a separate, dedicated CPSC monitoring system with serial-number-level matching.

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.

Fix: Treat every CPSC appliance recall alert as a Day 0 event requiring immediate portfolio-wide matching.

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.

Fix: Build a complete recall ticket package: CPSC notice + tenant notification + invoice + serial-number photos + completion certificate.

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.

Fix: Achieve ≥85% serial number coverage in your appliance registry before relying on any recall monitoring system.

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.

Fix: Create a separate, high-priority recall remediation workflow that bypasses standard maintenance queues and triggers immediate management attention.
The Common Thread

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.

Self-Assessment: Rate yourself 1 (not started) → 5 (fully implemented) Max score: 25
1. Registry Completeness
% of units with documented appliance serial numbers
2. Monitoring Speed
Can you detect a relevant recall within 1 hour of CPSC publication?
3. Response Protocol Clarity
Does everyone know what to do on Day 0 of a recall event?
4. Documentation Quality
Can you produce court-admissible documentation for any past recall?
5. Certification Capability
Can you generate a per-unit compliance certificate for each incident?
Your Compliance Score
0 / 25
20–25
Protected
Strong compliance posture. Focus on automation to reduce manual burden.
12–19
At Risk
Partial compliance. Specific gaps expose you to liability. Act on low scores first.
Under 12
Immediate Action
High exposure. An active recall event today would be unmanageable with your current system.

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: The AB 628 Compliance Layer for Your PM Stack

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.

RecallProof

Start Your Free Portfolio Recall Scan

Upload your appliance registry and get an instant report on which units have active CPSC recall exposure. before your next tenant lease renewal.

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