PFAS-Free Cleaning Products: What the 2024 GSA Specification Update Means for Institutional Procurement

Who this is for

This guide is for institutional procurement staff, facilities directors, and BSC contract managers who specify or purchase custodial chemicals for government buildings, universities, healthcare systems, K-12 schools, or any facility where federal contracting standards or state green procurement policies influence purchasing decisions. If you manage federal contracts, this is directly applicable. If you do not, the framework it establishes is increasingly being adopted by state agencies, university systems, and large healthcare networks as their own specification baseline.

What the 2024 GSA update requires

Under a Biden administration executive order implemented through GSA’s Federal Acquisition Regulation (FAR) process, federal agencies managing GSA Schedule custodial contracts are required to procure cleaning and janitorial products that do not contain intentionally added per- and polyfluoroalkyl substances (PFAS). The directive applies to products purchased under GSA Schedule 56 (Buildings and Building Materials) and associated janitorial supply schedules.

PFAS — a class of thousands of synthetic fluorinated compounds — have been used in cleaning product formulations primarily as surfactants, stain repellents, and wetting agents. The GSA directive does not require testing of every product for trace PFAS contamination; it requires that manufacturers certify that PFAS have not been intentionally added to the formulation. This is a formulation disclosure requirement, not an environmental detection threshold.

For non-federal institutional buyers, the practical question is: which third-party certifications verify this requirement without requiring independent manufacturer audits?

EPA Safer Choice and Green Seal as verification tools

Two third-party certification programs explicitly screen for PFAS in cleaning product formulations:

EPA Safer Choice

EPA’s Safer Choice program evaluates each ingredient in a cleaning product against safety criteria for human health and environmental impact. PFAS are prohibited under Safer Choice formulation requirements. A product bearing the Safer Choice label has been reviewed at the ingredient level by EPA, and PFAS have been verified as absent from the intentional formulation. The 2024 Safer Choice Standard update (finalized in August 2024) introduced a new service provider certification tier that allows BSCs to document their program’s chemical compliance at the portfolio level — relevant for contract language. See our guide to the EPA Safer Choice 2024 update and service provider certification for details on the new tier.

Green Seal GS-37

Green Seal’s GS-37 standard for commercial and industrial cleaners similarly prohibits PFAS in certified formulations. Green Seal certification is recognized in many state green procurement programs and is accepted under the GSA specification as evidence of PFAS-free status. For facilities responding to state-level green procurement requirements alongside or instead of federal requirements, GS-37 certification is often the more directly applicable standard.

Product categories most affected

Not all cleaning product categories have historically used PFAS at the same rate. The categories where PFAS formulation has been most prevalent — and where procurement staff should prioritize specification review — are:

• Floor finishes and floor polishes: Fluoropolymer compounds were historically used in floor finish formulations to improve soil resistance and leveling. Many floor finish manufacturers have reformulated, but legacy product inventory in distribution channels may not meet current requirements. Verify the specific product’s formulation date and certification status.
• Hard-surface degreasers: Some solvent-blend and fluorosurfactant-containing degreasers used PFAS compounds as wetting agents. Any degreaser without Safer Choice or GS-37 certification should be reviewed against current formulation data.
• Fabric protectants and carpet treatments: Historically the highest-PFAS category in custodial use. Stain-resistant carpet treatments based on PTFE or related fluoropolymers are subject to the GSA requirement and face the most replacement pressure.
• Disinfectants: Generally low PFAS risk in formulation, but verify if the product contains surfactant blends from manufacturers with legacy fluorosurfactant product lines.

The VOC Compliance Checker can help you assess whether substitution products meet applicable VOC limits in your state, since PFAS-free reformulations sometimes involve solvent substitutions that affect VOC content.

How non-federal buyers can use this framework

For universities, healthcare systems, and state agencies not directly subject to the GSA requirement, the most defensible approach to PFAS-free procurement is specifying EPA Safer Choice or Green Seal GS-37 certification in the product specification. This shifts the verification burden to an independently audited certification rather than requiring buyers to evaluate each manufacturer’s formulation disclosure independently.

Contract language that works: “All custodial chemical products supplied under this contract must carry a current EPA Safer Choice certification or Green Seal GS-37 certification at the time of delivery. Manufacturer certification of PFAS-free formulation without third-party verification does not satisfy this requirement.”

Common mistakes

Accepting manufacturer “PFAS-free” claims without certification documentation. Self-certification does not satisfy the GSA requirement or most institutional procurement policies. Require the specific certification number and expiration date for Safer Choice or Green Seal, not a marketing claim.

Assuming reformulated products meet VOC requirements in your state. Some PFAS-free reformulations introduce different solvent systems that may create new VOC compliance issues under CARB or state air quality rules. Evaluate the full formulation change, not just the PFAS removal.

Overlooking floor finish in the specification scope. Floor finish is often managed by a different budget line or vendor than other custodial chemicals, and it is the highest-risk category for historical PFAS use. Ensure it is explicitly included in the PFAS-free specification scope.

Quick checklist

• Identify which contracts or accounts are subject to GSA PFAS-free requirements directly
• Specify EPA Safer Choice or Green Seal GS-37 certification in contract language for non-federal accounts adopting the standard
• Audit current floor finish, degreaser, and carpet treatment products first — highest-risk categories
• Request current certification documentation (number and expiration) from distributors, not just a marketing claim
• Check that PFAS-free substitute products meet applicable state VOC limits before specifying
• Review product inventory for older stock that may pre-date reformulation