Federal & California law requirements, enforceability standards, and when disclaimers fail in court
Disclaimers of warranties CAN limit or eliminate certain liabilities—but ONLY if they comply with strict federal and state law requirements. Courts frequently strike down disclaimers that are hidden, contradictory, unconscionable, or violate consumer protection statutes.
Disclaimers must be in BOLD, UPPERCASE, or otherwise clearly visible—not buried in fine print.
Must mention "merchantability" and "fitness" by name to disclaim those implied warranties.
If you promise "99% uptime," disclaimers that negate that promise are unenforceable.
Federal Magnuson-Moss Act and state consumer laws limit disclaimers in consumer transactions.
Disclaimers do not protect sellers from liability for fraud, misrepresentation, or concealed defects.
Courts strike down one-sided disclaimers in "take-it-or-leave-it" consumer contracts.
This guide emphasizes California Commercial Code § 2316 and Song-Beverly Consumer Warranty Act, but the principles apply broadly across U.S. jurisdictions through the Uniform Commercial Code (UCC).
Citation: 15 U.S.C. § 2301 et seq.
If a seller provides ANY written warranty to a consumer for a consumer product, the seller CANNOT disclaim implied warranties entirely. The seller can only limit the duration of implied warranties to the duration of the written warranty—and must do so conspicuously. (15 U.S.C. § 2308)
Mirrors: UCC § 2-316 (adopted in all 50 states with variations)
Citation: Cal. Civil Code § 1790 et seq.
The Song-Beverly Act provides mandatory warranties for consumer goods sold in California. Disclaimers that attempt to eliminate these statutory protections are VOID. This includes "Lemon Law" protections for vehicles and other consumer products.
| Aspect | Federal (Magnuson-Moss) | California State Law |
|---|---|---|
| Scope | Consumer products with written warranties | All sales of goods; broader coverage |
| Implied Warranty Disclaimers | Cannot fully disclaim if written warranty given | Can disclaim if conspicuous + proper language |
| Consumer Goods | Song-Beverly adds mandatory protections | Song-Beverly mandatory warranties cannot be disclaimed |
| B2B Transactions | Generally not covered | UCC rules apply; more flexibility for disclaimers |
| Enforcement | FTC + private lawsuits | State courts + private lawsuits |
For a disclaimer to be enforceable, it must be: (1) Conspicuous, (2) Clear and unambiguous, (3) Use specific statutory language, (4) Not contradict express warranties, and (5) Not violate public policy or consumer protection laws.
Definition (Cal. Com. Code § 1201(b)(10)): A term is conspicuous if it is written or displayed in a way that a reasonable person against whom it is to operate ought to have noticed it.
Must mention "merchantability" by name. Example: "SELLER SPECIFICALLY DISCLAIMS THE IMPLIED WARRANTY OF MERCHANTABILITY." Alternatively, use "AS IS" or "WITH ALL FAULTS" language if conspicuous.
Must be in writing and conspicuous. Example: "THERE ARE NO WARRANTIES WHICH EXTEND BEYOND THE DESCRIPTION ON THE FACE HEREOF" or "SELLER MAKES NO WARRANTY THAT THE GOODS ARE FIT FOR ANY PARTICULAR PURPOSE."
If your marketing states "99.9% uptime guaranteed" or "this AI achieves 98% accuracy," disclaimers that attempt to disclaim "all express or implied warranties" are ineffective as to those specific promises. Courts uphold the express warranty and strike down contradictory disclaimers.
Under UCC § 2-313 / Cal. Com. Code § 2313:
Courts don't care if the seller "didn't intend" to create a warranty. If the buyer reasonably relied on a statement as a guarantee, it's an express warranty—even if the seller later disclaims it.
| Statement | Express Warranty? | Why? |
|---|---|---|
| "99.9% uptime guarantee" | ✅ YES | Specific performance promise |
| "This AI achieves 95% accuracy" | ✅ YES | Affirmation of fact about quality |
| "Best software on the market" | ❌ NO (puffery) | Subjective opinion, not verifiable |
| "Works with all major browsers" | ✅ YES | Description/compatibility promise |
| "You'll love this product!" | ❌ NO (puffery) | Opinion, not factual promise |
Once created, express warranties cannot be disclaimed if the disclaimer contradicts the promise. If disclaimers conflict with an express warranty, courts uphold the warranty and void the disclaimer. The only way to "disclaim" is to not make the promise in the first place.
Automatic for merchants: Arises by operation of law when a merchant sells goods of the kind they regularly deal in.
Arises when:
| Factor | Express Warranty | Implied Warranty |
|---|---|---|
| Source | Seller's explicit statements/promises | Operation of law (UCC) |
| Creation | Affirmation, description, sample/model | Automatic (merchantability for merchants) |
| Can be disclaimed? | ❌ NO (if contradicts promise) | ✅ YES (with proper language + conspicuousness) |
| Required language | N/A (cannot disclaim) | Must mention "merchantability" or "fitness" |
| Examples | "99% uptime," "works with all browsers" | Product must be fit for ordinary use |
Courts regularly strike down disclaimers for being hidden, contradictory, unconscionable, or in violation of consumer protection laws. Plaintiffs have multiple avenues to challenge disclaimers and recover damages.
Plaintiff argument: The disclaimer was buried in fine print, hidden in a browsewrap link, or overshadowed by marketing claims.
Plaintiff argument: Seller made specific promises (in marketing, sales materials, or contract) that contradict disclaimers.
Two-part test (UCC § 2-302, Cal. Civil Code § 1670.5):
Courts use a "sliding scale"—the more procedurally unconscionable (e.g., hidden, adhesive), the less substantive unconscionability needed, and vice versa. If both present to some degree, disclaimers can be struck down.
Plaintiff argument: Seller knowingly concealed defects or made fraudulent statements.
Plaintiff argument: Never agreed to or had notice of disclaimers.
(1) B2B transaction between sophisticated parties, (2) Disclaimers are conspicuous and mention "merchantability/fitness," (3) No express warranties contradict disclaimers, (4) No consumer protection statutes apply, (5) No fraud or concealment, (6) Buyer affirmatively acknowledged/signed disclaimers.
Follow these best practices to maximize the likelihood your disclaimers will withstand judicial scrutiny.
DISCLAIMER OF WARRANTIES. THE PRODUCTS ARE PROVIDED "AS IS" AND "WITH ALL FAULTS." SELLER SPECIFICALLY DISCLAIMS ALL IMPLIED WARRANTIES, INCLUDING THE IMPLIED WARRANTY OF MERCHANTABILITY AND THE IMPLIED WARRANTY OF FITNESS FOR A PARTICULAR PURPOSE. SELLER MAKES NO REPRESENTATION OR WARRANTY REGARDING THE PRODUCTS' PERFORMANCE, QUALITY, OR SUITABILITY FOR BUYER'S INTENDED USE.
Disclaimers hidden behind small "Terms of Service" links at bottom of webpage (browsewrap) are frequently deemed inconspicuous and unenforceable. Always use clickwrap or sign-in wrap for consumer-facing disclaimers.
"Seller is not liable for anything under any circumstances, including fraud, negligence, or breach of contract."
"Seller disclaims all implied warranties of merchantability and fitness. This disclaimer does not limit Seller's liability for fraud, gross negligence, or personal injury caused by Seller's willful misconduct."
| Type | How It Works | Enforceability |
|---|---|---|
| Clickwrap | User must click "I agree" checkbox or button after being presented with terms | ✅ HIGH - Courts generally enforce if terms are visible |
| Sign-in Wrap | User clicks "Sign Up" or "Create Account" with notice that doing so accepts terms | ✅ MODERATE-HIGH - Enforceable if notice is clear |
| Browsewrap | Terms accessible only via small hyperlink (e.g., footer link to "Terms of Service") | ❌ LOW - Often deemed inconspicuous and unenforceable |
A return policy (e.g., "30-day return for full refund") is NOT the same as a warranty disclaimer. Return policies are voluntary seller policies. Warranty disclaimers attempt to limit legal liability. Disclaimers cannot override statutory return/refund rights in some states.
Courts split on whether software is a "good" under the UCC or a "service." Many treat software licenses as mixed transactions (goods + services). Regardless:
Sample SaaS Disclaimer Language:
THE SERVICES ARE PROVIDED "AS IS" AND "WITH ALL FAULTS." COMPANY DISCLAIMS ALL WARRANTIES, EXPRESS OR IMPLIED, INCLUDING IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, AND NON-INFRINGEMENT. COMPANY DOES NOT WARRANT THAT THE SERVICES WILL BE UNINTERRUPTED, ERROR-FREE, OR SECURE, OR THAT DATA WILL NOT BE LOST OR CORRUPTED.
AI Product Disclaimer:
THE AI SERVICES ARE PROVIDED "AS IS" WITHOUT WARRANTY OF ANY KIND. COMPANY SPECIFICALLY DISCLAIMS ANY WARRANTY THAT AI OUTPUTS WILL BE ACCURATE, COMPLETE, OR FREE FROM ERRORS OR BIAS. USER ACKNOWLEDGES THAT AI MODELS PRODUCE PROBABILISTIC RESULTS THAT MAY VARY AND SHOULD NOT BE RELIED UPON FOR CRITICAL DECISIONS WITHOUT INDEPENDENT VERIFICATION. COMPANY DISCLAIMS ALL IMPLIED WARRANTIES OF MERCHANTABILITY AND FITNESS FOR A PARTICULAR PURPOSE, INCLUDING FITNESS FOR MEDICAL, LEGAL, FINANCIAL, OR SAFETY-CRITICAL APPLICATIONS.
If your marketing claims "95% accuracy guaranteed" or "bias-free AI," disclaimers cannot negate those express warranties. Align marketing claims with actual disclaimers, or risk liability.
Disclaimers cannot eliminate duties imposed by privacy statutes. You cannot disclaim compliance with CCPA, GDPR, HIPAA, or other data protection laws. Disclaimers only address contractual warranties, not statutory obligations.
THIS IS BETA SOFTWARE PROVIDED FOR TESTING PURPOSES ONLY. THE SOFTWARE IS PROVIDED "AS IS" WITHOUT ANY WARRANTY WHATSOEVER. COMPANY DISCLAIMS ALL WARRANTIES, EXPRESS OR IMPLIED, INCLUDING MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, AND NON-INFRINGEMENT. BETA SOFTWARE MAY CONTAIN ERRORS, BUGS, AND SECURITY VULNERABILITIES. USER ASSUMES ALL RISK FOR USE OF BETA SOFTWARE.
Whether you're drafting disclaimers for your business or challenging disclaimers as a plaintiff, attorney guidance is essential to navigate the complex interplay of federal law, state law, and contract principles.
Draft enforceable warranty disclaimers tailored to your business, products, and jurisdictions.
Ensure disclaimers comply with Magnuson-Moss, Song-Beverly, UCC, and consumer protection laws.
Review existing terms for contradictions, conspicuousness issues, and enforceability gaps.
Challenge unenforceable disclaimers on grounds of unconscionability, fraud, or statutory violations.
Negotiate settlements, mediate warranty disputes, or litigate breach of warranty claims.
Specialized guidance for SaaS, AI, and digital product disclaimers in online transactions.
Schedule a 30-minute consultation to review your warranty disclaimers, contract terms, or potential claims.
Email: owner@terms.law
Sergei Tokmakov, Esq. | California Bar #279869
Email: owner@terms.law
Practice Focus: Business Contracts, Disputes, E-commerce, Technology Law