Executive Order 14057, the federal sustainability order, was revoked. The Revolutionary FAR Overhaul Part 23 model deviation removes the two clauses that rested on it — 52.223-20 (Aerosols) and 52.223-21 (Foams) — and retitles Part 23, consolidating every remaining prescription under 23.108.
The second half of that is the part that catches people.
The surviving clauses kept their numbers, so a matrix built on clause numbers alone looks fine. But every
prescription moved from 23.109 to 23.108. If your solicitation template prints the
authority next to the clause, it is now citing a subsection that prescribes nothing.
| Clause | Title | Was prescribed at | Status |
|---|---|---|---|
| 52.223-20 | Aerosols | 23.109(d)(3) | Removed & reserved |
| 52.223-21 | Foams | 23.109(d)(4) | Removed & reserved |
Both were discretionary clauses under the legacy regime, so a contracting officer who never used them will notice no change. The exposure is in templates that included them by default.
| Clause | Title and applicability | Prescription moved |
|---|---|---|
| 52.223-23 | Sustainable Products and Services All acquisitions | 23.109(a)→23.108(a) |
| 52.223-9 | Estimate of Percentage of Recovered Material Content for EPA-Designated Items Supplies over $200,000 CO discretion | 23.109(b)(2)→23.108(b)(2) |
| 52.223-11 | Ozone-Depleting Substances and High Global Warming Potential Hydrofluorocarbons Supplies CO discretion | 23.109(d)(1)→23.108(d)(1) |
| 52.223-12 | Maintenance, Service, Repair, or Disposal of Refrigeration Equipment and Air Conditioners Services CO discretion | 23.109(d)(2)→23.108(d)(2) |
52.223-23 is the only Part 23 clause the deviation keeps as a mandatory requirement. The other three remain contracting officer discretion items, exactly as they were under the legacy regime — the deviation did not change any clause from mandatory to discretionary or back.
30 agencies, on dates from 3 November 2025 to 18 May 2026:
| Adopted | Agencies |
|---|---|
| 2025-11-03 | DHS GSA HUD NSF* USDA |
| 2025-11-05 | VA |
| 2025-11-14 | MCC |
| 2025-11-21 | HHS |
| 2025-11-26 | CFTC |
| 2025-12-01 | DOL SEC UDALL |
| 2025-12-08 | DOJ |
| 2025-12-09 | DOT |
| 2025-12-10 | NRC |
| 2025-12-19 | NASA |
| 2025-12-22 | CPSC |
| 2026-01-07 | TREASURY |
| 2026-01-14 | DOE |
| 2026-01-15 | DOC |
| 2026-01-30 | ED |
| 2026-02-01 | DOD NARA |
| 2026-02-03 | PBGC |
| 2026-02-13 | EPA |
| 2026-02-19 | SSA |
| 2026-02-27 | DOS |
| 2026-04-29 | OPM |
| 2026-05-12 | FCC |
| 2026-05-18 | DOI |
* NSF: the posted file is a later supplement that does not give the base deviation's date, so the table shows the government-wide base date, 3 November 2025.
Adoption data as of 2026-10-23. If your agency is not listed, the legacy Part 23 clause set still governs — including 52.223-20 and 52.223-21, and the 23.109 prescriptions.
Not at an agency that has adopted the Revolutionary FAR Overhaul Part 23 model deviation. Both rested on Executive Order 14057, and the deviation removes and reserves them following its revocation. At an agency that has not adopted Part 23, the legacy clauses still apply.
The clause numbers did not change, but their prescriptions did. Part 23 was retitled and its prescriptions consolidated under 23.108, so 52.223-23 moves from 23.109(a) to 23.108(a), 52.223-9 from 23.109(b)(2) to 23.108(b)(2), 52.223-11 from 23.109(d)(1) to 23.108(d)(1), and 52.223-12 from 23.109(d)(2) to 23.108(d)(2).
Because a clause matrix or solicitation template that cites the prescription is now citing a subsection that no longer prescribes anything under the deviation. The clause is still correct; the authority printed next to it is not.
Yes. It is the one Part 23 clause the deviation keeps as a non-discretionary requirement, prescribed at 23.108(a). The other three survivors are contracting officer discretion items, as they were under the legacy regime.
As of 2026-10-23, 30 agencies, adopting between 3 November 2025 and 18 May 2026, so which clauses apply depends on both your agency and your solicitation date.
ArcClause resolves the legacy and deviation clause sets against your agency and solicitation date, and prints the prescription it actually used — so a renumbered cite shows up before the solicitation does.
Related: FAR Part 22 labor clauses after E.O. 11246 · FAR Part 40 security clauses · FAR overhaul tracker