Procurement language that says "cleaning products must be environmentally preferable" without specifying a certification standard and scope has no enforceable meaning. A product labeled "green" or "eco-friendly" with no third-party certification can make almost any claim. Green Seal certification, specifically GS-37 for institutional cleaners and GS-40 for floor care products, is the standard with the clearest ingredient-level requirements, documented testing protocols, and independent verification. Understanding what the standard actually requires, and what it doesn't cover, is the first step to writing a procurement specification that means something.
What GS-37 and GS-40 Actually Require
Green Seal GS-37 covers general purpose and institutional cleaners including bathroom cleaners, glass cleaners, carpet cleaners, and all-purpose cleaners. The standard sets requirements in three areas: ingredient hazard (prohibiting specific chemicals including specific surfactants, fragrances, and preservatives identified as high-hazard), VOC content limits (pH-specific limits that vary by product category), and cleaning performance (verified by standardized test protocols that the product must pass).
GS-40 covers floor care products including floor finishes, floor strippers, and floor maintenance products. The standard requirements parallel GS-37 in structure but include specific performance criteria for floor finish durability and stripper efficiency. GS-40 requires VOC content limits of 30 g/L or less for floor strippers and defined gloss retention minimums for floor finishes. Both standards require that the certified product be tested by an independent Green Seal-approved laboratory and that the certification be maintained through annual review.
What neither standard addresses: disinfectant efficacy (disinfectants are regulated by EPA under FIFRA, not by Green Seal), occupational safety beyond ingredient hazard (OSHA regulates that separately), and supply chain sustainability beyond the product formulation itself. A procurement program that specifies GS-37 cleaners and GS-40 floor care products but uses unregistered disinfectants, non-certified carpet chemicals, and high-VOC solvents in other categories has a partial green program, not a comprehensive one.
GS-37 Requirements by Product Category
| Category | VOC Limit | Key Prohibited Ingredients | Performance Requirement |
|---|---|---|---|
| General purpose cleaner | pH dependent: 3% max for pH 6-8 | Alkylphenol ethoxylates, NTA, specific preservatives | Soil removal test |
| Bathroom/restroom cleaner | 3% max | HCl, phosphoric acid (some formulations), NTA | Soil removal and surface compatibility |
| Glass cleaner | 5% VOC max | Alkylphenol ethoxylates | Streak-free cleaning test |
| Carpet cleaner (pre-spray) | 3% max | NTA, specific solvent-based spotters | Soil removal on standard test carpet |
GS-40 Requirements for Floor Care Products
| Category | VOC Limit | Key Requirements | Performance Test |
|---|---|---|---|
| Floor finish | 115 g/L max | No PFAS, no tributyltin, specific plasticizer restrictions | Gloss retention, scuff resistance, film clarity |
| Floor stripper | 30 g/L max | No diethylene glycol monobutyl ether above threshold | ASTM F1650 removability test |
| Floor restorer/maintainer | 115 g/L max | No PFAS, ingredient hazard screen | Gloss retention after multiple cleaning cycles |
The PFAS restriction in GS-40 for floor finishes is significant: many traditional high-gloss floor finishes historically used PFAS compounds (specifically fluorinated polymers) to improve leveling, gloss, and chemical resistance. GS-40 certified finishes must achieve performance specifications without PFAS chemistry. Check the PFAS state lookup tool for state-specific PFAS restrictions that may apply to floor care products beyond GS-40 certification, as some states have enacted PFAS prohibitions in cleaning products that are broader than the GS-40 standard.
How Green Seal Certification Works in Practice
Green Seal certification is product-specific: a manufacturer's certification of one product line does not extend to other products in their catalog. The certified product carries the Green Seal mark on the label with the standard number (GS-37 or GS-40). Procurement specifications that require "products meeting Green Seal criteria" without requiring the certification mark allow substitution of uncertified products with unverifiable claims. The specification should require the certification mark on the label or documentation from Green Seal's certified products directory.
Green Seal maintains a searchable product database that allows buyers to verify current certification status. Certifications have expiration dates and can be suspended for non-compliance. Purchasing a "Green Seal certified" product that was certified 4 years ago without verifying current certification status is a documentation risk in audit contexts.
Where Green Seal Certification Earns Its Place
Green Seal certification earns its place as a procurement specification for school districts with indoor air quality policies, healthcare facilities with occupant safety mandates, government contracts with green purchasing requirements, and commercial building accounts pursuing LEED O+M credits for sustainable cleaning. The education cleaning hub covers the application of GS-37 specifications in K-12 and higher education programs where state green purchasing mandates are increasingly common.
Green Seal certification is less relevant for industrial accounts where cleaning performance under heavy soil conditions requires chemistry that exceeds GS-37's VOC or pH limits. There is a real performance tradeoff in some heavy industrial applications: GS-37 compliant degreasers may not achieve the same throughput on heavy petroleum soil as conventional alkaline or solvent formulations. The tradeoff paragraph is required, and in industrial contexts it is real.
Regulatory Interface
Green Seal certification is a voluntary third-party certification, not a regulatory requirement. However, it is referenced in federal green procurement guidelines (EPA's Recommendations for Purchasing Programs for Cleaning Products), numerous state green purchasing programs, and LEED v4 and v5 O+M prerequisites. The Federal Acquisition Regulation's sustainable acquisition preferences direct agencies to prefer EPA Safer Choice and Green Seal certified cleaning products. For accounts with federal tenants or government facility management contracts, GS-37 and GS-40 specifications are often contractual, not optional.
The ASTM test methods referenced in GS-40 (including F1650 for floor polish removability) provide the performance verification framework that makes Green Seal certification independently verifiable, not just self-reported.
Tradeoffs
GS-37 and GS-40 certified products carry a price premium relative to conventional formulations in most categories: 15 to 40 percent on most product categories in competitive bid scenarios. The labor and liability cost reduction from reduced occupant exposure incidents, reduced IAQ complaints, and regulatory compliance documentation are real but difficult to quantify in the bid line. Accounts with documented green procurement requirements have no choice. Accounts without requirements face a procurement decision where the chemistry performance and safety case for certified products must be made independently of the certification mark, because the mark alone doesn't win the contract against a lower-priced conventional alternative.
What to Specify on the Bid Line
Specify the standard by number (GS-37 or GS-40), require the certification mark on the product label or current documentation from the Green Seal certified product directory, and specify the product categories covered by the certification requirement. Not all cleaning products have GS-37 equivalents: disinfectants require EPA FIFRA registration rather than Green Seal certification, and these two requirements must be specified separately for accounts that need both cleaning and disinfection compliance. See EPA Safer Choice and DfE cleaners for the parallel sustainability certification framework, visit the chemicals library for the full product landscape, and use the VOC compliance tool to verify that certified products meet any additional state-level VOC requirements beyond Green Seal minimums.
By the Opora Editorial Team · Last updated: 2026