23andMe · 23andMe Terms of Service · View original document ↗

Sample Processing Failure and Refund Protocol

Medium severity High confidence Explicitdocumentlanguage Unique · 0 of 343 platforms
Share 𝕏 Share in Share 🔒 PDF
Monitor governance changes for 23andMe Create a free account to receive the weekly governance digest and monitor one platform for governance changes.
Create free account No credit card required.
Document Record

What it is

If your DNA sample fails processing twice, you get a full refund minus shipping costs, but you are barred from resubmitting a new sample through a future purchase of the service.

This analysis describes what 23andMe's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

This provision both limits the financial remedy for a persistent processing failure and restricts the user from ever repurchasing the service to try again, which is an operationally distinct restriction not commonly observed in standard consumer product return policies.

Recent Activity

This document changed recently

Medium May 5, 2026

The updated Terms now apply only to users who live outside the United States, Canada, EEA, UK, and Switzerland, or who access the Services from outside those regions. US, Canadian, EEA, UK, and Swiss users are directed to region-specific Terms instead. Additionally, when terms for a specific Service conflict with the main Terms, the specific Service terms now govern that portion of your use rather than the main Terms controlling. The mandatory arbitration provision remains in the document but is no longer prominently featured at the very beginning of the Terms.

View change record →
High Apr 19, 2026

The updated Terms of Service now apply exclusively to users in the United States, narrowing the geographic scope from the prior version that addressed users in multiple regions. The terms now contain a prominently featured mandatory arbitration provision that requires disputes to be resolved through individual arbitration on an individual basis rather than through jury trials or class action lawsuits. This means that if a user has a dispute with 23andMe, the updated terms require arbitration as the method of resolution instead of traditional litigation. Additionally, if a user purchases additional services, the main Terms of Service (including the arbitration provision) will control any conflicting terms from those additional services. You can review the complete updated Terms of Service through the link provided in the document.

View change record →
Medium Mar 23, 2026

The updated terms now apply only to users who live outside or access services outside the United States, Canada, EEA, UK, and Switzerland. Previously, the terms applied to US-based users. The terms also clarify that when service-specific terms conflict with the general Terms of Service, the service-specific terms will govern that particular service rather than the general terms controlling all conflicts. This means users of additional services may operate under different dispute resolution and governance procedures depending on which service they are using.

View change record →

Clause Stability Stable

0
Changes
3
Months Monitored
May 12, 2026
First Seen
May 22, 2026
Last Seen
This clause type exists across 71 other provisions on other platforms.

Consumer impact (what this means for users)

Users whose samples fail the second processing attempt receive a refund minus shipping and handling but are contractually prohibited from submitting another sample through a future purchase of the same service, effectively barring them from accessing 23andMe's genetic testing if they fall into the 0.65% persistent failure category.

How other platforms handle this

Skillshare High

Skillshare has no obligation to consider or grant refund requests, including (i) for subscription plans purchased with a 7-day or longer free trial; or (ii) that otherwise do not follow our Refund Policy. To the extent permissible under applicable law, you are entitled to, at most, one refund only.

Hulu Medium

EXCEPT AS REQUIRED BY APPLICABLE LAW, WE DO NOT REFUND OR CREDIT FOR PARTIALLY USED SUBSCRIPTION TERMS AND/OR BILLING PERIODS, ALTHOUGH WE MAY PROVIDE SUCH REFUNDS OR CREDITS ON A CASE-BY-CASE BASIS IN OUR SOLE AND ABSOLUTE DISCRETION. IF YOUR SUBSCRIPTION IS CANCELED DUE TO FAILED ATTEMPTS TO CHARG...

Microsoft Medium

Unless otherwise provided by law or by a particular Service offer, all purchases are final and non-refundable. If you believe that Microsoft has charged you in error, you must contact us within 90 days of such charge. No refunds will be given for any charges more than 90 days old.

See all platforms with this clause type →

Monitoring

23andMe has changed this document before.

Receive same-day alerts, structured change summaries, and monitoring for up to 25 platforms.

Start Monitor free trial Or create a free account →
▸ View Original Clause Language DOCUMENT RECORD
"
If the second attempt to process the sample is unsuccessful, (up to 0.65% of all samples fail the second attempt at testing according to 23andMe data obtained in 2019 for all genotype testing),* 23andMe will not send additional sample collection kits and the user will be entitled solely and exclusively to a complete refund of the amount paid to 23andMe, less shipping and handling, provided the user shall not resubmit another sample through a future purchase of the Service.

— Excerpt from 23andMe's 23andMe Terms of Service

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

REGULATORY LANDSCAPE: The conditional refund structure and the restriction on future purchases may engage state consumer protection statutes that govern the adequacy of consumer remedies for product failures. The FTC's rules on deceptive practices could apply if the restriction on future purchases is not clearly disclosed at the point of sale. State refund and return laws, particularly in California, may impose minimum refund rights that take precedence over the shipping and handling deduction stated here. GOVERNANCE EXPOSURE: Medium. The prohibition on future sample submission following a double processing failure is an operationally specific restriction that compliance teams should evaluate for adequate pre-purchase disclosure. The refund being limited to amounts paid less shipping and handling is a standard commercial practice, but the additional prohibition on future purchases is a less common remedy restriction. JURISDICTION FLAGS: California's consumer protection framework may impose obligations on 23andMe to disclose the future purchase restriction prominently before sale. The shipping deduction from refunds should be evaluated under applicable state refund laws in California, New York, and other states with specific refund disclosure requirements. CONTRACT AND VENDOR IMPLICATIONS: The tiered reprocessing protocol creates an operational obligation for laboratory partners to document and report processing failure rates. Organizations purchasing kits in bulk for employee or research use should evaluate how persistent sample failures affect their aggregate refund and replacement rights. COMPLIANCE CONSIDERATIONS: Legal teams should confirm that the future purchase prohibition is disclosed in pre-sale product descriptions and not only in the Terms of Service. The citation of 2019 data for failure rate statistics should be reviewed for currency and whether updated data changes the disclosed risk profile.

Full compliance analysis

Regulatory citations, enforcement risk, and due diligence action items.

Track 1 platform — free Try Monitor free for 14 days

Free: track 1 platform + weekly digest. Monitor: 25 platforms + same-day alerts. No credit card required.

Applicable agencies

  • FTC
    The FTC has authority over consumer product refund practices and the adequacy of pre-sale disclosures regarding remedy limitations
    File a complaint →
  • State AG
    State attorneys general may evaluate the future purchase prohibition and shipping deduction from refunds under state consumer protection and refund statutes
    File a complaint →

Applicable regulations

FTC Act Section 5
United States Federal

Provision details

Document information
Document
23andMe Terms of Service
Entity
23andMe
Document last updated
May 5, 2026
Tracking information
First tracked
May 11, 2026
Last verified
May 12, 2026
Record ID
CA-P-010918
Document ID
CA-D-00147
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
16a44b36aa17e55ddf47ae29310c84ef467de0a10b43cf99d04895259b10a9f1
Analysis generated
May 11, 2026 23:34 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: 23andMe
Document: 23andMe Terms of Service
Record ID: CA-P-010918
Captured: 2026-05-11 23:34:45 UTC
SHA-256: 16a44b36aa17e55d…
URL: https://conductatlas.com/platform/23andme/23andme-terms-of-service/sample-processing-failure-and-refund-protocol/
Accessed: June 27, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

Other risks in this policy

Compliance Governance Intelligence

Need to monitor specific governance provisions?

Compliance includes provision-level monitoring, governance timelines, regulatory mapping, and audit-ready analysis.

Arbitration clauses AI governance Data rights Indemnification Retention policies
Start Compliance free trial

Or start with Monitor →

Built from archived source documents, structured governance mappings, and historical version tracking.

Frequently Asked Questions

What does 23andMe's Sample Processing Failure and Refund Protocol clause do?

This provision both limits the financial remedy for a persistent processing failure and restricts the user from ever repurchasing the service to try again, which is an operationally distinct restriction not commonly observed in standard consumer product return policies.

How does this clause affect you?

Users whose samples fail the second processing attempt receive a refund minus shipping and handling but are contractually prohibited from submitting another sample through a future purchase of the same service, effectively barring them from accessing 23andMe's genetic testing if they fall into the 0.65% persistent failure category.

Is ConductAtlas affiliated with 23andMe?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by 23andMe.