Cleaning supplies feel like the easy buy: paper, liners, soap, floor products. For a federal buyer they come with two checks that have to happen in a set order. First, is there a source you are required to use? Second, if not, which environmental rules apply to what you pick?
We are a supplier, not your contracting office, so this is the view from the other side of the order. It is also what we see go wrong: a requisition that names a product with no thought to the mandatory source, or a "green" requirement that says nothing a supplier can actually verify. This guide covers both checks in plain English, written for a purchase card holder or a facility buyer.
Step one: check the required sources of supply
Before you look at price or brand, find out whether the item has to come from a specific place. FAR 8.002 sets a priority order for supplies. Unless other law says otherwise, agencies are directed to look first at these sources, in this order:
- Your own agency's inventories.
- Excess property from other agencies.
- Federal Prison Industries (FPI, also called UNICOR).
- Supplies on the AbilityOne Procurement List.
- Wholesale supply sources such as GSA, the Defense Logistics Agency and the Department of Veterans Affairs.
For janitorial buyers the one that matters most is number four. Cleaning and custodial products are among the items on the AbilityOne Procurement List, and FAR subpart 8.7 makes those items mandatory. If an item is on the list, you buy it from the designated nonprofit agency or an authorized AbilityOne distributor. The same subpart says no other FAR provision creates an exception to that rule. Section 8.002(c) adds that the obligation reaches contractors too, when they buy listed items for government use.
Two points get missed:
- It is the item, not the category. "Trash can liners" is not on the list. A specific liner, to a specific specification, may be. You check the exact item.
- Mandatory source applies at every dollar value. Being under the micro-purchase threshold does not remove it. Cardholders are expected to check the list too.
How to check the Procurement List
The AbilityOne Commission publishes the list at abilityone.gov. It has a product search and downloadable spreadsheets of products and services. Search by the item description or the national stock number if you have one. If your agency orders through GSA, DLA or VA catalogs, listed items are marked as a mandatory source in those catalogs.
If the item is on the list, you order through the channel the program names. That is the end of the sourcing question for that line.
When a listed item can come from somewhere else
Subpart 8.7 allows buying a listed item commercially only under a purchase exception, which is granted by the central nonprofit agency, not by you. Exceptions exist when the nonprofit cannot meet the time or quantity you need, or cannot produce it economically. The contracting officer starts purchase action within 15 days of the exception and sends the solicitation to the central agency. Do not treat "it was cheaper somewhere else" as an exception. It is not one.
Where Federal Prison Industries fits
FPI sits above AbilityOne in the supply priority. Janitorial products are less often an FPI issue than furniture is, but the check is the same: is the item on the FPI Schedule, and if so, what does FAR subpart 8.6 require? We cover that process in our guide to UNICOR waivers for office furniture.
Step two: the green purchasing rules
If no mandatory source covers your item, the sustainable purchasing rules decide what you can pick. They live in FAR subpart 23.1, and they apply to all contract actions, including purchases at or below the micro-purchase threshold. That includes a card purchase.
The policy in section 23.103 is that agencies buy sustainable products and services to the maximum extent practicable. Buying them is presumed practicable unless you cannot get them competitively, on a reasonable schedule, meeting reasonable performance needs, at a reasonable price. Price reasonableness can take life-cycle cost into account.
The rules come in layers. Subpart 23.1 sets the priority: statutory programs first, then multi-attribute sustainable products, then products meeting required EPA programs. For cleaning supplies four programs come up most.
Recovered content (EPA-designated items)
Some products are designated by EPA as items that should contain recovered material. Paper towels, tissue and trash bags are the janitorial examples. Under FAR 23.107-1, once the agency buys more than $10,000 of a designated item in a fiscal year (counting micro-purchases), it must run an affirmative procurement program with a preference for recovered content. As a buyer you do not run that program, but you will see its effect: specifications that call for a minimum recovered content, or the highest practicable content.
Biobased products (USDA BioPreferred)
USDA's BioPreferred program designates categories of biobased products, 142 of them at last check, and each has a minimum biobased content. The categories include cleaners. Under FAR 23.107-2, agencies prefer products in those categories that meet the minimum. The program publishes a catalog of USDA Certified Biobased Products, and the certification label means a third party verified the biobased content. If a product claims to be biobased, ask for the certification or the catalog listing, not a marketing line.
EPA Safer Choice
FAR 23.108-2 lists Safer Choice as a required EPA purchasing program. Buy products meeting it to the maximum extent practicable once the statutory programs are met. Safer Choice is an EPA label for products with safer ingredients. EPA provides a product finder that lets you search certified cleaners by category. Disinfectants are handled separately, through EPA's list of certified disinfectants. Use the finder to verify a product. Do not rely on the word "green" on a label.
EPA's recommendations of specifications, standards and ecolabels
FAR 23.108-3 points to EPA's Recommendations of Specifications, Standards, and Ecolabels for Federal Purchasing. EPA says these cover more than 60 private-sector standards and ecolabels across more than 40 categories. The page has a category filter, so look up cleaning products there to see which third-party labels EPA recognizes. Check it at the time you buy, because EPA updates it.
The clause you may see: 52.223-23
If your purchase goes beyond a card swipe, the solicitation or contract will probably include FAR 52.223-23, Sustainable Products and Services. The version on acquisition.gov is dated May 2024. In practice it says that the products the contract covers must meet the applicable program standards when the offer is submitted, and must meet EPA's recommendations as they stood in October 2023. It also points contractors to the Green Procurement Compilation at sftool.gov to work out which programs apply.
Older solicitations may cite other clause numbers, such as 52.223-2 for biobased reporting on service and construction contracts. FAR 23.109 lists which clauses go where. Because the FAR is being rewritten and agencies issue deviations, read the clause in your actual solicitation rather than assuming.
One caution. Section 23.102 cites an executive order that a notice on the same page says has been revoked. We do not read that as a repeal of the FAR text, which still says agencies shall buy sustainable products. It does mean you should check your agency's current policy on how it applies the rule.
A short checklist for the buyer
- Search the AbilityOne Procurement List for the exact item. If listed, order through the named source.
- Check the FPI Schedule if your category could be there.
- If neither applies, decide which green attributes your requirement needs: recovered content, biobased content, Safer Choice, a recognized ecolabel.
- Write each attribute as a checkable statement. "Safer Choice certified" can be verified. "Eco-friendly" cannot. Our guide to writing salient characteristics has the pattern.
- Ask the supplier to cite the certification for each line, with the listing or certificate attached.
- Keep the check in the file. If you bought under the card, a note on what you checked is enough.
For card purchases, read micro-purchase threshold and paying a supplier by government purchase card for the other rules that apply to the transaction.
How Lunula Supply handles it
When a requirement comes in for cleaning or facility supplies, we start with the sourcing question. We check whether the item looks like a listed item and tell the buyer what we find, instead of quoting around it. When the requirement is open, we quote to the written specification, and we confirm the certification for each green attribute before we price it. We label the sourcing channel on every line (manufacturer, distributor or retail), and we ask before any substitution.
If you have a janitorial requirement and want a small business source that will confirm the details line by line, send it to us or see what we supply. Our broader view of what to expect after award is in what to expect from a government supplier.
Frequently asked questions
Do I have to check the AbilityOne list for a purchase card buy?
Yes. The mandatory source rules in FAR subpart 8.7 do not carry a dollar exception, and the program says federal customers must buy listed items from the designated nonprofit or an authorized distributor. Check the exact item before you buy.
Do the green purchasing rules apply to small purchases?
Yes. FAR subpart 23.1 says it applies to all contract actions, including those at or below the micro-purchase threshold. The affirmative procurement programs for recovered content and biobased products are triggered by yearly dollar amounts at the agency level, but the buying preference still reaches individual purchases.
How do I verify a Safer Choice or biobased claim?
Use the program's own finder. EPA provides a searchable list of Safer Choice certified products, and USDA publishes a catalog of certified biobased products. Ask your supplier to cite the listing for each line.
Can I buy a listed item cheaper somewhere else?
Not on price alone. A listed item can be bought commercially only under a purchase exception granted by the central nonprofit agency, which applies when the nonprofit cannot meet the time or quantity required or cannot produce it economically.
General information, not legal advice. References were checked against acquisition.gov, epa.gov, biopreferred.gov and abilityone.gov on the publish date, and the FAR is changing, so confirm the current text. Your agency's policy and contract terms control.