Trump Administration Rolls Back Federal Sustainable Procurement Rules

Date: November 16, 2025
Author: Daniel A. Eisenberg, Beveridge & Diamond PC

Overview

The Trump administration has initiated a significant rollback of sustainable procurement mandates embedded in the Federal Acquisition Regulation (FAR), specifically targeting rules enacted under the Biden administration less than two years ago. By issuing class deviations from the FAR—bypassing the traditional notice-and-comment rulemaking process—the administration is simplifying and narrowing sustainability requirements for federal contractors.

Background: Biden Era Sustainable Procurement Rules

• April 2024 Final Rule: Implemented under Executive Order 14057, the rule required federal agencies to procure sustainable products and services to the maximum extent practicable.
• Key Provisions:
  • Definition of “sustainable products and services” expanded to include service contracts.
  • New contract clause FAR 52.223-23 applicable to both supplies and services.
  • Agencies had to identify sustainable products and services in solicitations, referencing EPA-endorsed programs such as ENERGY STAR, WaterSense®, and Safer Choice certification.
• Scope: Extended sustainable procurement beyond goods to include cloud services, IT maintenance, and facility management contracts, increasing demand for green products like EPEAT-registered electronics.

Trump Administration Rollback Details

• Scope Reduction:
  • Removes “services” from the sustainable procurement definition.
  • Narrows “sustainable products” to only those covered by certain statutory programs:
    • EPA’s Comprehensive Procurement Guidelines (recovered materials)
    • ENERGY STAR and Federal Energy Management Program (FEMP) energy-efficient products
    • USDA BioPreferred® biobased products
    • EPA’s Significant New Alternatives Policy (SNAP) for ozone-safe substances
• Dropping EPA Non-Statutory Programs: Eliminates references to WaterSense®, Safer Choice®, and other EPA recommendations.
• Implementation via Class Deviations: Avoids slow formal rulemaking; agencies may alter solicitation language immediately, creating potential short-term relief for contractors on sustainability obligations.

Implications for Federal Contractors and Industry

• Reduced Regulatory Pressure: Contractors currently investing heavily in sustainable goods and services face increased competition from firms not bound by previously stricter mandates.
• Market Uncertainty: The temporary nature of class deviations means sustainability requirements could be reinstated or altered by future administrations, adding compliance risk.
• Supply Chain and Contracting Impact: Contractors must monitor evolving FAR clauses closely, adapt bid strategies, and reassess investments in green product and service offerings to remain competitive.

Conclusion

This rollback represents a strategic pivot away from Biden-era federal sustainability goals. While simplifying procurement rules, it potentially slows the federal government’s market-driving role in promoting sustainable products and services. Industry stakeholders should remain vigilant to rapidly changing FAR language and prepare for potential regulatory shifts in sustainable procurement policies.

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