The Complete AB 628 Compliance Guide for California Property Managers

On January 1, 2026, California property management changed overnight. Assembly Bill 628 (AB 628) amended Civil Code §1941.1 to make working stoves and refrigerators a statutory tenantability requirement. and it put a 30-day countdown on every recalled appliance in your portfolio.

If you manage rental properties in California. whether you oversee 5 units or 5,000. AB 628 compliance isn't optional. It's the law. And the penalties for non-compliance are steep: rent abatement, repair-and-deduct claims, punitive damages, and financial exposure that can exceed $65,000 per incident.

This guide breaks down everything you need to know about AB 628 compliance as a property manager: what the law requires, the hidden "constructive knowledge" trap that catches most managers off guard, the full financial consequences of non-compliance, and a 10-step checklist you can implement starting today.

1. What Is AB 628?

AB 628 is a California state law. formally, Assembly Bill 628. that took effect on January 1, 2026. It amends Civil Code §1941.1, the statute that defines what makes a rental dwelling "habitable" under California law.

In plain English: AB 628 makes functioning stoves and refrigerators a legal requirement in every California rental unit. Landlords must provide and maintain both appliances in proper working order. If either appliance is subject to a federal safety recall, the landlord has 30 days from the date of notice to repair or replace it.

Before AB 628, California's habitability statute covered things like waterproofing, plumbing, heating, electricity, and sanitation. Appliances were conspicuously absent. While courts sometimes ruled that a non-functioning stove or refrigerator could contribute to uninhabitable conditions (as in Camacho v. Schaefer), the law itself didn't explicitly list them.

AB 628 closes that gap and goes further: it specifically addresses recalled appliances. A stove or refrigerator under an active CPSC (Consumer Product Safety Commission) recall is legally treated as non-functional for habitability purposes. even if it still turns on and appears to work fine.

This is a significant shift. It means a perfectly operational Samsung range sitting in your tenant's kitchen could be creating a habitability violation right now. if there's an active recall you don't know about.

2. What AB 628 Actually Requires

Let's get specific about the obligations AB 628 places on California landlords and property managers:

The 30-Day Remediation Deadline

When a recall is issued for an appliance in a rental unit, the property manager has 30 calendar days from the date of notice to repair or replace the affected appliance. This isn't a suggestion. it's a hard statutory deadline.

"Repair" means completing the remedy specified in the recall (usually a manufacturer-provided fix or modification). "Replace" means swapping the recalled appliance for a non-recalled, functionally equivalent unit.

What Counts as "Notice"?

This is where AB 628 gets teeth. "Notice" doesn't just mean receiving a letter from the manufacturer. Under the doctrine of constructive knowledge (more on this in the next section), notice may be triggered the moment a recall appears on CPSC.gov.

In practical terms: your 30-day clock may start ticking the day the CPSC publishes the recall. regardless of whether you've personally seen the announcement.

The Tenant Addendum Exception

There is one exception. If a tenant signs a written addendum stating they are providing their own appliance (e.g., they brought their own refrigerator), the landlord's obligation to maintain that specific appliance is modified. However, this exception is narrow:

• The addendum must be signed at lease inception or renewal. not after the fact
• It must clearly identify which appliance the tenant is providing
• The landlord may still have obligations if the tenant's appliance poses a safety hazard
• If the landlord later replaces the appliance, full AB 628 obligations resume

For most property managers, the practical takeaway is straightforward: if you provided it, you maintain it. and that includes monitoring it for recalls.

3. The "Constructive Knowledge" Trap

If there's one concept that should keep California property managers up at night, it's constructive knowledge. This is the legal principle that will determine most AB 628 liability. and it's the one most managers don't fully understand.

Here's how constructive knowledge works in the context of AB 628:

California courts have long held that landlords are responsible for knowing about conditions that would be discoverable through reasonable diligence. In Becker v. IRM Corp. (38 Cal.3d 454, 1985), the California Supreme Court established that landlords can be strictly liable for defective conditions. regardless of actual knowledge.

AB 628 extends this doctrine to appliance recalls. The CPSC recall database is a public record, freely available online at CPSC.gov. Under a constructive knowledge standard, a court will likely reason that a professional property manager should be checking this database. and therefore knew or should have known about any published recall.

What This Means in Practice

Consider this scenario: The CPSC publishes a recall for a specific Samsung range model on March 1. You manage 200 units and 14 of them have that Samsung model. You don't find out about the recall until a tenant sends you an article about it on April 15. 45 days later.

Under a constructive knowledge standard, your 30-day remediation window started on March 1. By April 15, you're already 15 days past the deadline on all 14 units. Each of those 14 units represents an independent habitability violation with independent financial exposure.

This is the constructive knowledge trap: ignorance is not a defense. The recall information was publicly available, you had a duty to monitor for it, and your tenants' rights activated the moment it was published. regardless of when (or whether) you personally became aware.

For property managers who have never actively monitored the CPSC recall database. which, candidly, is most property managers. this means AB 628 created an entirely new compliance obligation that requires proactive, ongoing monitoring.

4. What Happens If You Don't Comply

The consequences of AB 628 non-compliance aren't theoretical. California tenant protection law provides multiple, stackable remedies. and tenants are increasingly aware of them.

Tenant Remedies Under California Law

• Rent abatement: Tenants can claim a percentage reduction in rent for the period the unit was uninhabitable. Courts use the Cazares v. Ortiz formula (109 Cal.App.3d Supp. 23) to calculate the proportional reduction. For a recalled appliance that presents a fire hazard, abatement percentages can be substantial.
• Repair-and-deduct (Civil Code §1942): Tenants can arrange the repair themselves and deduct the cost from rent. up to one month's rent per repair. With California rents averaging $2,000+, this can be significant.
• Retaliation damages: If a landlord retaliates against a tenant who reports a recalled appliance, the tenant can recover actual damages plus punitive damages up to $2,000 per act, plus attorney's fees. This applies to any adverse action (rent increase, eviction notice, service reduction) within 180 days of the tenant's complaint.
• Constructive eviction claims: If the habitability violation is severe enough. say, a recalled range with documented fire hazard. the tenant may claim constructive eviction, terminate the lease without penalty, and sue for damages including relocation costs.
• Tort claims: If a recalled appliance causes injury or property damage, the landlord faces personal injury liability. Given that many appliance recalls involve fire and burn hazards, this exposure is potentially catastrophic.

The Real Financial Exposure

When you stack these remedies, the financial exposure per incident ranges from $10,000 to $65,000+ per affected unit. Here's a conservative breakdown:

The Case That Set the Precedent

In Camacho v. Schaefer (193 Cal.App.3d 718, 1987), a tenant successfully sued a landlord over habitability violations in a single rental unit. The court awarded $33,100 in damages plus $17,500 in attorney's fees. a total of $50,600. Adjusted for inflation and modern California rents, an equivalent judgment today would be even higher.

Now multiply that by every unit in your portfolio that contains a recalled appliance. For a mid-size property management company with 500+ units, a single undetected recall affecting a common appliance model could create six-figure aggregate liability.

5. The 10-Step AB 628 Compliance Checklist

Whether you're a solo landlord with a duplex or an operations director at a 3,000-unit REIT, AB 628 compliance comes down to the same core steps. Here's the complete checklist:

1. Inventory All Appliances Build a complete database of every landlord-provided appliance: make, model number, serial number, unit location, and installation date. Start with stoves and refrigerators (covered by AB 628), but include all appliances for comprehensive protection.
2. Run a Historical Recall Audit Cross-reference your entire inventory against the CPSC recall database at CPSC.gov. Identify any appliances currently under active recall. Prioritize these for immediate remediation. your 30-day clock may have already started.
3. Verify Lease Addendums Review every lease for tenant-provided appliance addendums. Document which units have tenant-owned appliances and which units have landlord-provided appliances. Ensure addendums are properly signed and filed.
4. Set Up Continuous Recall Monitoring Establish a system for ongoing monitoring of CPSC recall announcements. At minimum, check CPSC.gov weekly. For reliable AB 628 compliance, consider automated recall monitoring that matches recalls against your specific inventory in real time.
5. Establish a 30-Day Remediation Workflow Create a standard operating procedure for when a recall is detected: who gets notified, who contacts the OEM, who schedules the repair/replacement, and who tracks the deadline. Document every step.
6. Document OEM Contacts & Repair Programs Build a contact sheet for major appliance manufacturers' recall/repair departments. Many OEMs (Whirlpool, Samsung, GE) have dedicated property manager hotlines and will cover repair costs. Having these contacts ready saves days when a recall hits. See the OEM reimbursement section below.
7. Create Tenant Notification Templates Prepare template letters for notifying tenants about recalled appliances, scheduling repairs, and confirming completion. Include information about the recall, the remediation timeline, and any interim safety instructions from the OEM.
8. Prepare RecallCert™ Documentation For every recall remediation, maintain a complete paper trail: date of recall discovery, date of tenant notification, OEM communication records, repair/replacement receipts, and completion confirmation. This documentation is your defense if a tenant later claims non-compliance.
9. Train Maintenance Staff Ensure your maintenance team knows the AB 628 requirements: what triggers a recall obligation, the 30-day deadline, how to identify model/serial numbers, and the importance of documentation. Every team member who touches appliances should understand the law.
10. Schedule Quarterly Reviews Set a recurring calendar reminder to review your compliance posture quarterly: re-audit your appliance inventory, verify monitoring is working, check for any missed recalls, and update your documentation. AB 628 compliance isn't a one-time project. it's an ongoing operational requirement.

Want this in a printable format with timeline templates? Get the free AB 628 Compliance Guide PDF →

6. How Many Recalls Are We Talking About?

Property managers often underestimate the volume and frequency of appliance recalls. Here are the numbers:

What This Means for Your Portfolio

Let's do the math for a typical mid-size portfolio:

• 500 units under management
• 6 appliances per unit (stove, refrigerator, dishwasher, microwave, washer, dryer)
• 3,000 total appliances in the portfolio
• At 0.5-2% annual recall incidence: 15 to 60 individual appliances could be affected by a recall in any given year

Even at the low end, that's roughly 1-2 active recalls per year that you need to detect, track, and remediate within 30 days. Miss one, and you're looking at the liability numbers we discussed in Section 4.

For institutional operators managing 2,000+ units, the math is starker: you're statistically guaranteed to have recalled appliances in your portfolio at any given time. The question isn't whether you have them. it's whether you know about them.

Consider recent high-profile examples: the Samsung slide-in electric range recall (CPSC #24-335) affected units responsible for approximately 250 fires and 40 injuries. The AstroAI mini-refrigerator recall (CPSC #25-086) covered 249,000 units with 70 overheating incidents and 2 fires causing $360,000 in property damage. The Midea window air conditioner recall (CPSC #25-320) impacted a staggering 1.7 million units sold under brands like Frigidaire, Danby, and Keystone.

Any of these could be installed in your portfolio right now.

7. Manual Monitoring vs. Automated Solutions

There are two ways to approach AB 628 recall monitoring: the manual way and the automated way. Both are technically compliant. But they differ dramatically in cost, reliability, and risk.

The Manual Approach

Manual monitoring means assigning someone on your team to regularly check the CPSC recall database, cross-reference every new recall against your appliance inventory, and manage the remediation process through spreadsheets and email.

The real cost of manual monitoring isn't the $2,500 in labor. it's the risk. A staff member who checks CPSC.gov every Friday morning will miss any recall published over a long weekend until Tuesday. A property manager on vacation might not check for two weeks. And when staff turns over (which happens frequently in property management), the process often breaks entirely.

For a small landlord with a handful of units and a few appliances, manual monitoring may be adequate. if you're disciplined about it. For anyone managing 50+ units, the math favors automation: the cost of one missed recall ($10,000-$65,000+) dwarfs the annual cost of an automated recall tracking solution.

8. OEM Manufacturer Reimbursement

Here's the silver lining that many property managers don't know about: most recall remediations cost you nothing. Major appliance manufacturers have dedicated recall programs that reimburse property managers for parts, labor, and sometimes full unit replacement.

To take advantage of OEM reimbursement programs, you need three things:

1. Speed: Contact the manufacturer promptly after the recall is announced. Reimbursement programs sometimes have claim windows.
2. Documentation: Keep records of the appliance's model/serial number, the recall number, repair invoices, and completion confirmation.
3. The right contact: Many OEMs have separate channels for property managers vs. individual consumers. The property manager channel is faster and offers higher reimbursement rates.

This flips the cost equation: AB 628 compliance can actually be cost-neutral or even cost-positive if you catch recalls quickly and use manufacturer programs. The only scenario where recalls get expensive is when you don't catch them. and end up paying for tenant remedies instead of manufacturer reimbursement.

9. How RecallProof Automates AB 628 Compliance

We built RecallProof specifically to solve the AB 628 compliance challenge. Here's how it works:

1. Upload your appliance inventory. Import via CSV, connect to your property management software, or enter manually. RecallProof catalogs every appliance by make, model, serial number, and unit location.
2. 24/7 real-time monitoring. RecallProof continuously watches the CPSC database, manufacturer announcements, and safety bulletins. When a new recall is published, it's automatically matched against your inventory within hours. not days or weeks.
3. Instant alert when a match is found. If a recalled appliance is in your portfolio, your team gets an immediate alert with the recall details, affected units, recommended action, and OEM contact information.
4. 30-day remediation tracking. RecallProof tracks the remediation deadline for every affected unit, sends escalation reminders as the deadline approaches, and flags overdue items. No recall falls through the cracks.
5. RecallCert™ documentation. Every step of the compliance process is automatically logged: detection date, notification records, repair scheduling, completion confirmation, and OEM reimbursement status. This creates a court-ready documentation package for each remediation.
6. $1M Total Coverage Guarantee. We stand behind our monitoring with a guarantee: if a recall slips through RecallProof's monitoring and you incur damages, we cover it. up to $1 million. (Subject to terms and conditions; see Service Level Agreement for details.)

For property managers who are currently tracking recalls manually (or not at all), RecallProof replaces the spreadsheet-and-prayer approach with systematic, documented, defensible compliance.

10. Frequently Asked Questions