U.S. EPEAT Electronic Product Environmental Certification: The Legal Basis for Federal Procurement Mandates and 2026 Program Expansion
Overview
EPEAT (Electronic Product Environmental Assessment Tool) is a voluntary Type 1 ecolabel program that evaluates the entire lifecycle of electronic products—design, manufacturing, packaging, energy use, and end-of-life design—and is administered by the Global Electronics Council (GEC), a nongovernmental third-party organization. In federal procurement, Federal Acquisition Regulation (FAR) Subpart 23.7 requires federal agencies to procure EPEAT-registered and ENERGY STAR-certified products for covered electronic product categories such as computers and workstations. This legal basis traces back to Executive Order 14057 of 2021 (Executive Order on Federal Sustainability), under which EPA had continuously recommended expanding the EPEAT procurement categories (adding solar modules, power purchase agreements, energy savings performance contracts, networking equipment, and other categories). While Executive Order 14057 itself was rescinded by the Trump administration in January 2025 (see us-federal-buy-clean-initiative-full), because the legal basis for the EPEAT procurement mandate is also grounded in the separate regulation FAR Subpart 23.7, the federal procurement mandate for EPEAT-registered products itself remains in effect as of August 2026. This point supports GRI's Level 2 assessment ("no change"). The program itself continues to expand in 2026. In 2026, GEC conducted a 60-day public comment period (closing June 21, 2026) on a proposal to introduce a new category, "EPEAT Renew," covering reused and refurbished electronics (such as laptops). GEC also solicited public comment between January and March 2026 on the GEC Criteria Development Process (P74) and Product Category Selection (P75)—foundational documents governing program operations—and has published revised versions. Furthermore, "EPEAT Climate+," a higher-tier certification imposing additional greenhouse gas emissions and supply chain transparency criteria on top of EPEAT's highest tier, "EPEAT Gold," is also increasingly being incorporated into federal agency procurement specifications.
Enforcement Timeline
December 2021: President Biden's Executive Order 14057 expands the recommended EPEAT federal procurement categories
January 2025: Executive Order 14057 is rescinded, but the EPEAT procurement mandate under the Federal Acquisition Regulation (FAR Subpart 23.7) continues
January–March 2026: The Global Electronics Council (GEC) publishes revised versions of its foundational standards (P74/P75)
June 21, 2026: The public comment period closes for the new "EPEAT Renew" category covering refurbished and remanufactured equipment
Business Impact
Vendors supplying PCs, servers, and IT equipment to the U.S. federal government continue to be subject to EPEAT registration and ENERGY STAR certification requirements under FAR Subpart 23.7, even after the rescission of the executive order. Companies will also need to address compliance with new categories such as EPEAT Climate+ and "EPEAT Renew" for refurbished products.
