This guide explains FAR Part 23 of the Federal Acquisition Regulation (FAR), with practical examples for federal contractors.
Watch the FAR Part 23 video
FAR Part 23: environmental requirements
Environmental rules in a federal contract, under the Federal Acquisition Regulation, can feel like a maze. When a reviewer asks how you know a requirement applies, the strongest answer is not confidence. It is evidence. Let's build that evidence, step by step. Start with the map. The codified FAR Part 23 is titled Environment, Sustainable Acquisition, and Material Safety. It has four pieces you will meet again and again, and each answers a different question.
FAR Subpart 23.1 covers sustainable products and services. FAR Subpart 23.2 covers energy savings performance. FAR Subpart 23.3 covers hazard identification, safety data sheets, and radioactive material notice. FAR Subpart 23.4 covers pollution prevention and waste. Notice these are different jobs: what you buy, how energy is saved, what hazards you disclose, and how waste is handled. One document cannot prove all four. Within sustainable products, keep three programs separate: recovered materials, biobased products, and energy efficient products.
Sustainable purchasing and hazard communication
Each is its own category. A claim in one is not a claim in another. A green claim needs a specification and evidence. Saying a product is eco-friendly proves nothing. Point to the exact requirement in the solicitation, then to the document showing your product meets it. Scope matters too. The codified 23.1 scope includes commercial items, COTS, and micropurchases. But check your agency for current deviations, because the rule that applies to you may be worded differently.
One caution. Do not treat the revoked Executive Order 14057 as controlling, or assume every older ecolabel or greenhouse gas provision is current. None of those is universal. Mandatory law applies separately from whether a clause appears. Your actual clauses and the law both matter. The codified FAR is the baseline. Agency deviations implement the rewritten FAR text, and agency adoption is not the same as a codified amendment.
So read what your solicitation actually incorporates. Now the safety data sheet. An SDS tells you what hazards a product carries and how to handle it. It does not prove the product is sustainable, and it does not replace a hazard notice your contract requires. Likewise, radioactive material notice and hazard disclosure are obligations in their own right. If a clause requires notice, you give that notice.
Check clauses, product evidence, and agency deviations
A green label or an SDS cannot stand in for it. Here is a hypothetical. Northfield Supply is bidding to deliver cleaning products to a federal facility. The solicitation mentions sustainable products, safety data sheets, and waste. The team wants to write, we are fully compliant. The capture manager asks instead: for every statement, what is our proof? What follows is our own business exercise, not an added FAR requirement.
Take each requirement one at a time and attach evidence. Requirement one: sustainable content. If the solicitation names recovered materials or biobased content, Northfield needs the actual specification and a manufacturer record for each product, not marketing copy. Requirement two: energy. Only if an item actually falls under an applicable energy efficient product program, show its qualifying documentation. If it does not, Northfield must not claim it.
Evidence decides what the claim can say. Requirement three: safety data. If the solicitation requires safety data sheets, provide a current one for each covered product, with revision dates on file. That is evidence for the hazard requirement only, not for any green claim. Requirement four: waste. If the solicitation requires a waste procedure, describe the actual procedure for handling product waste and containers, and keep the records.
Build a defensible purchasing file
Waste handling is its own obligation, separate from certifying the product itself. Requirement five: hazard notices. Check whether the contract requires notice about hazardous or radioactive material. If so, name who sends it and when. Disclosure is a duty, not a marketing point. Put it in a table: the requirement quoted with its clause number, the source and any deviation, your claim in one plain sentence, the evidence, and an owner with a review date.
No evidence means ask the contracting officer. Assign roles. The contracts lead flags environmental clauses. The technical lead matches products to documents. The quality lead checks SDS currency. An independent reviewer tests every claim before submission and delivery. Open the acquisition.gov FAR Part 23 page, then your own solicitation, and check for agency deviations. Build the table for your next bid. Visit govsuccess.com for more.
This guide is educational, not legal advice.
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