Sustainable Acquisition

Sustainable acquisition is the overarching federal procurement policy that directs agencies to consider the full environmental and social lifecycle impact of their purchasing decisions, going beyond simple product attributes to encompass supplier practices, greenhouse gas emissions, and long-term resource stewardship.

What is Sustainable Acquisition?

Sustainable acquisition is codified primarily in FAR Subpart 23.1 (Sustainable Acquisition Policy) and implemented through a series of overlapping executive orders, most recently E.O. 14057 (2021). The policy requires that federal agencies, to the maximum extent practicable, purchase:

• Products and services that are energy- and water-efficient.
• Products that contain recovered materials (recycled content).
• Biobased products designated under USDA's BioPreferred program.
• Products that minimize toxic or hazardous substances.
• Products with reduced greenhouse gas footprints.
• Environmentally preferable products as defined by EPA's purchasing guidelines.

Beyond product characteristics, sustainable acquisition increasingly encompasses:

• Supplier greenhouse gas (GHG) disclosure - E.O. 14057 requires major contractors to publicly disclose their GHG emissions and set science-based reduction targets.
• Clean energy transition - agencies are directed to procure electricity from clean energy sources and reduce building fossil fuel use.
• Supply chain resilience - reducing dependence on single-source suppliers for critical materials.
• Social sustainability - labor standards, responsible sourcing, and supply chain due diligence for conflict minerals (Dodd-Frank Section 1502).

FAR 52.223-series clauses implement specific sustainable acquisition requirements at the contract level. Contracting officers must include applicable clauses based on the product or service category and contract value.

Why Sustainable Acquisition matters for government contractors

The GHG disclosure requirements in E.O. 14057 are expanding. Major contractors (those with $50 million or more in annual federal contracts) will face increasing requirements to report Scope 1, 2, and eventually Scope 3 emissions and set reduction targets. Early investment in emissions tracking systems and sustainability reporting infrastructure positions contractors to meet these requirements without disruption.

Example

A defense logistics firm holding multiple large contracts implements an enterprise sustainability program in anticipation of E.O. 14057 GHG reporting requirements. The firm inventories its Scope 1 and 2 emissions from vehicle fleets and facilities, registers with CDP (formerly Carbon Disclosure Project) to provide a public disclosure, and sets a science-based target of 50 percent reduction by 2030. This positions the firm to meet emerging FAR sustainability clauses and differentiates it in best-value evaluations where agencies award evaluation credit for demonstrated sustainability commitments.

Frequently Asked Questions

What is the difference between sustainable acquisition and green procurement?

Green procurement focuses on specific product attributes (recycled content, energy efficiency, biobased content). Sustainable acquisition is the broader strategic policy that encompasses green procurement plus GHG emissions management, clean energy sourcing, supply chain social standards, and long-term resource stewardship. All green procurement is part of sustainable acquisition, but sustainable acquisition extends beyond product purchasing to organizational and supply chain behavior.

Are contractor GHG reporting requirements mandatory now?

As of mid-2026, FAR rulemaking is progressing to implement E.O. 14057's GHG disclosure requirements. Significant contractors (defined by annual federal contract revenue thresholds) will face phased mandatory disclosure requirements. Contractors should monitor FAR council rulemaking and begin GHG inventory processes before the rules are finalized.

Do sustainable acquisition requirements increase proposal complexity?

Yes, in some cases. Solicitations for major facility services, energy, IT equipment, and supplies increasingly include sustainability representation requirements and may evaluate green attributes as a technical factor. Contractors must verify product certifications, prepare sustainability representations, and in some cases document supply chain practices as part of their proposal submissions.

How do sustainable acquisition requirements interact with lowest-price procurement?

FAR sustainable acquisition requirements apply to all procurements regardless of evaluation methodology. Even a Lowest Price Technically Acceptable (LPTA) evaluation must specify the required sustainable product standards as mandatory technical acceptability criteria. A non-compliant product that offers the lowest price cannot be awarded the contract if it fails mandatory environmental requirements.