California property-scope guide

California Reportable Property and Exemptions

Use the property definition, transaction context, statutory exemptions, and current official guidance together. A business label or broad product category is not enough to decide whether an item must be reported.

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Guide at a glance

  • Covered-property framework
  • Coin, bullion, and ingot exclusions
  • Transaction and source exemptions
  • January 1, 2027 changes

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Educational resource—not legal advice. Requirements can depend on business activity, property type, transaction type, licensing status, local rules, and agency guidance. Confirm obligations with the California Department of Justice, your licensing authority, or qualified counsel.

Start with four questions

  1. Is the business acting as a secondhand dealer for this activity?
  2. Does the item fall within covered tangible personal property?
  3. Does a property or transaction exemption apply?
  4. What law was effective on the transaction date?

Do not use this page as an automatic report/do-not-report decision tool.

Property and transaction distinctions

Potentially covered property

California’s framework includes specified serial-numbered or inscribed property, pledged property, and property in applicable Attorney General classifications. Apply current statutes and official materials.

Jewelry needs item-specific review

The final AB 2633 does not create an all-jewelry rule. Characteristics, transaction context, classifications, and exemptions matter.

Excluded property remains

BPC § 21627(d) excludes coins, monetized bullion, and specified marked commercial-grade ingots, art bars, and medallions from tangible personal property under this article. The statutory definition includes assay-fineness and refiner/fabricator marking conditions for the specified precious-metal products; do not extend the exclusion to every bar or other item called bullion. The property exclusion does not cover other qualifying merchandise acquired by the same business. Coin-focused mixed-business guidance.

Transaction exemptions

BPC § 21629 includes specified interdealer, liquidation, judicial/government, previously reported, and precious-metal-related circumstances. Apply exact conditions.

New 2027 nonprofit and donated-item exemption

Beginning January 1, 2027, BPC § 21629 adds an exemption for property ‘acquired from a nonprofit organization or as a bulk purchase of donated items.’ The statute does not define ‘bulk’ or prescribe a documentary safe harbor. Record the basis for the decision and route uncertainty for qualified review.

Attorney General property-list change

Beginning January 1, 2027, the Attorney General continues to identify property constituting a ‘significant class of stolen goods,’ but the former statutory more-than-10% threshold is removed. Do not invent a replacement method or assume a CAPSS configuration until DOJ publishes it.

Practical property-review workflow

  1. Record the acquisition date and applicable law version.
  2. Identify the activity and transaction.
  3. Describe the item and available serial numbers, inscriptions, brands, models, materials, and marks.
  4. Check property exclusions and transaction exemptions.
  5. Record the facts supporting any claimed exemption.
  6. Escalate uncertain classifications rather than silently excluding a transaction.
  7. Monitor DOJ property tables and CAPSS resources.

Frequently asked questions

Are all jewelry purchases reportable?

No. The final AB 2633 does not create an all-jewelry rule.

Are coins still excluded in 2027?

Coins, monetized bullion, and qualifying ingots remain excluded property; that is not an entity-wide exemption for other acquisitions.

How many donated items make a purchase ‘bulk’?

AB 2633 does not specify a number.

Should dealers use the former 10% threshold after 2026?

No substitute should be invented. Monitor DOJ’s official methodology and property materials.

Official sources

Source materials may change. Confirm current law and agency instructions before acting.

Organize property and transaction records

EZ-CAPSS helps teams collect and retain information used in California reporting workflows. It does not decide whether an item is legally reportable or exempt.

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