Trump Administration Rolls Back Sustainable Procurement Rules in Federal Acquisition

Overview of the Rollback

In late 2025, the Trump administration reversed sustainable procurement requirements under the Federal Acquisition Regulation. The rollback undoes policies that the Biden administration set less than two years earlier. This change uses class deviations. These deviations work as a shortcut. They replace a longer notice-and-comment rulemaking process.

Background: Biden-Era Sustainability Mandates

On April 22, 2024, the Biden administration issued a final rule. The rule expanded sustainable procurement mandates under FAR Case 2022-006. Key aspects of that rule were:

• Broadened Scope: Agencies had to buy sustainable products and services as much as possible. This update was the first FAR change to include services like IT and facility management.
• New Definitions and Clauses: The rule set out a FAR 2.101 definition for sustainable products and services. It also introduced the FAR 52.223-23 contract clause.
• EPA Program Alignment: Agencies were told to follow EPA standards. They had to look at programs such as WaterSense®, Safer Choice, and ecolabels like EPEAT for electronics.
• Expanded Compliance Duties: Contractors had to prove that their supply chains met sustainability goals. They needed to show recovered materials, biobased content, energy and water efficiency, and safer chemical use.

Trump Administration’s Changes

The rollback now narrows sustainable procurement to products only. It removes services from FAR sustainability definitions. Key updates are:

• Restricted Definition: Sustainable products now cover only items defined by statutory purchasing programs. These include:
  • EPA’s Comprehensive Procurement Guidelines for recovered materials.
  • ENERGY STAR and the Federal Energy Management Program (FEMP) for energy efficiency.
  • USDA’s BioPreferred® program for biobased content.
  • EPA’s SNAP program for substitutes of ozone-depleting substances.
• Elimination of EPA Voluntary Programs: The rollback drops non-statutory EPA programs such as WaterSense® and Safer Choice.
• Simplification: FAR Parts 2 and 23 are streamlined. This reduces the overall scope of sustainable procurement requirements.

Implications for Industry and Federal Contractors

• Reduced Regulatory Pressure: The rollback shows reduced federal focus on green procurement mandates.
• Uncertainty in Contracting: Agencies may change or remove sustainability clauses in contracts before the FAR is permanently rewritten.
• Competitive Impact: Contractors who invested in sustainable product lines face more competition now that the requirements are relaxed.
• Potential Future Reinstatements: Since the rollback comes via deviations rather than new permanent rules, future administrations may bring back sustainability mandates.

Strategic and Regulatory Context

This rollback is part of a broader effort by the Trump administration. The effort, called the “Revolutionary FAR Overhaul,” targets simpler, less strict federal acquisition rules. The use of class deviations means changes can happen faster. This method cuts the need for lengthy public commentary. It marks a clear shift in federal procurement policy.

Sources

• Beveridge & Diamond PC, Client Alert, November 13, 2025
• FAR Case 2022-006 (Federal Acquisition Regulation amendments, April 2024)
• Executive Order 14057 (Catalyzing Clean Energy Industries and Jobs Through Federal Sustainability)
• U.S. EPA procurement programs (ENERGY STAR, WaterSense®, Safer Choice, EPEAT)
• USDA BioPreferred® Program

For businesses involved in federal contracts and focused on sustainability, it is essential to watch contract terms and solicitations closely. This vigilance will help adapt procurement strategies during this transitional period.

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