Navigating the Shift: Understanding the Trump Administration’s Rollback on Sustainable Procurement Policies

Trump Administration Rolls Back Sustainable Procurement in Federal Acquisition Regulation (FAR)

Date: November 13, 2025
Author: Daniel A. Eisenberg, Beveridge & Diamond PC

Background: Biden-Era Sustainable Procurement Rule

In April 2024, under the Biden administration, the Department of Defense, General Services Administration, and NASA amended the FAR to require federal agencies to procure sustainable products and services to the maximum extent practicable. This rule implemented Executive Order 14057 aiming to reduce federal emissions, promote environmental stewardship, and support clean energy industries.

Key features of the 2024 rule included:

• Broadening “sustainable products and services” definitions to include services such as IT and maintenance.
• New contract clause FAR 52.223-23 mandating contractor compliance with sustainable procurement.
• Inclusion of EPA’s voluntary programs like WaterSense®, Safer Choice, and EPEAT ecolabels in procurement standards.
• Emphasis on supply chain transparency and sustainability performance monitoring.

Trump Administration’s Rollback Initiative

The Trump administration is actively rolling back these requirements through a series of class deviations from the FAR, aiming to simplify and reduce sustainability mandates without engaging in full rulemaking.

Key rollback measures include:

• Removal of “services” from the sustainable procurement definition, narrowing focus strictly to products.
• Limiting sustainable products to only those covered under statutory purchasing programs such as:
  • EPA’s Comprehensive Procurement Guidelines (recovered materials).
  • ENERGY STAR and Federal Energy Management Program (FEMP) for energy efficiency.
  • USDA’s BioPreferred® program for biobased products.
  • EPA’s Significant New Alternatives Policy (SNAP) for safe chemical alternatives.
• Stripping all references to non-statutory EPA purchasing programs, removing WaterSense®, Safer Choice, and related eco-labels from federal criteria.

Implications for Sustainable and Federal Contractors

• Regulatory Uncertainty: The rollback is proceeding via deviations rather than formal notice-and-comment rulemaking, creating unpredictable short-term changes in solicitation language and contract clauses.
• Market Impact: Companies that invested in sustainability to comply with Biden-era mandates may encounter new competition as sustainability requirements loosen.
• Future Risks: Although the current administration reduces emphasis on “green” procurement, reversals remain possible under future administrations reinstating stricter sustainability rules.
• Supply Chain Adjustments: Contractors and manufacturers must remain agile to adjust compliance, tracking, and sustainability reporting according to evolving FAR provisions.

Strategic Shift in Regulatory Process

The Trump administration’s use of FAR class deviations represents a strategic move to bypass the longer formal rulemaking process, enabling rapid deregulation of federal procurement sustainability standards. This shift demands increased vigilance from industry players monitoring government contract solicitations and regulatory communications.

Conclusion

The rollback of sustainable procurement requirements marks a significant shift away from the growing trend of embedding sustainability into federal acquisitions. While offering short-term reprieve for contractors, it injects uncertainty into the market for sustainable products and services. Businesses engaged in federal contracting should closely track these evolving regulations to maintain compliance and competitive advantage in the changing procurement landscape.

References:

• FAR Case 2022-006 (April 2024 final rule)
• Executive Order 14057 (Catalyzing Clean Energy Industries and Jobs Through Federal Sustainability)
• EPA, USDA, and Federal Energy Management Program guidelines

This summary provides an expert legal and regulatory analysis of recent federal procurement policy developments affecting sustainable products and services.

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