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

Sample Processing Failure and Refund Protocol

Medium severity High confidence Explicitdocumentlanguage Unique · 0 of 325 platforms
Share 𝕏 Share in Share 🔒 PDF
Recent governance activity 23andMe recorded 4 documented changes in the last 30 days.
Start monitoring updates
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…

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…

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 a…

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

Midjourney Medium

Anyone attempting to violate our Community Guidelines using the Editor will face suspension or banning without refund. Use this tool with respect and consideration for others.

Coursera Medium

You agree to pay all fees or charges to your account in accordance with the fees, charges, and billing terms in effect at the time a fee or charge is due and payable. All fees are exclusive of all taxes, levies, or duties imposed by taxing authorities. You are responsible for payment of all such tax...

Unreal Engine Medium

Except as stated in Section 6(b), only Users (as defined in Section 9(c)) who have been assigned a Seat may access the Licensed Technology for the purpose of developing a Royalty-Free Product. 'Seat' means the right granted to you by Epic to allow one User to access and use the Licensed Technology o...

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 10 platforms.

Start Watcher 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 Watcher free for 14 days

Free: track 1 platform + weekly digest. Watcher: 10 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 →

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: May 13, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

Other risks in this policy

Professional Governance Intelligence

Need to monitor specific governance provisions?

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

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

Or start with Watcher →

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.