FAR 52.223-20—Aerosols.
Plain-English Summary
FAR 52.223-20, Aerosols, is a green procurement clause that limits the use of high global warming potential hydrofluorocarbons (HFCs) in aerosol propellants or solvents when the contract does not say otherwise. The clause defines the key terms needed to apply the requirement, including global warming potential, high global warming potential hydrofluorocarbons, and hydrofluorocarbons, and it points contractors to EPA’s Significant New Alternatives Policy (SNAP) program for acceptable substitutes. In practice, the clause requires the contractor to reduce the use, release, or emissions of these HFCs when feasible, and to evaluate feasibility using environmental, technical, and economic factors such as emissions, energy efficiency, safety, performance, and cost. It matters because it pushes contractors toward lower-impact aerosol formulations while preserving mission needs and product performance. The clause also creates a practical compliance expectation: contractors should actively check EPA SNAP alternatives rather than defaulting to legacy propellants or solvents. For contracting officers, it is a tool to implement federal environmental policy in acquisitions involving aerosol products or aerosol-related services.
Key Rules
Key definitions control scope
The clause defines global warming potential, high global warming potential hydrofluorocarbons, and hydrofluorocarbons so users know exactly which substances are covered. These definitions are essential because the restriction applies only to the specified class of HFCs and only where EPA’s SNAP program has identified lower-GWP alternatives for a particular end use.
Reduce HFC use when feasible
Unless the contract says otherwise, the contractor must reduce its use, release, or emissions of high global warming potential HFCs from aerosol propellants or solvents when feasible. This is a performance-based requirement, not an absolute ban, so the contractor must make a reasonable substitution effort where alternatives exist.
Feasibility must be evaluated broadly
When deciding whether an alternative is feasible, the contractor must consider environmental, technical, and economic factors. The clause specifically calls out in-use emission rates and energy efficiency, safety concerns such as flammability or toxicity, ability to meet technical performance requirements, and commercial availability at a reasonable cost.
EPA SNAP is the reference source
The contractor must refer to EPA’s SNAP program to identify acceptable alternatives. The clause directs users to 40 CFR part 82, subpart G, and EPA’s supplemental tables, making SNAP the primary source for determining whether a lower-GWP substitute is available for the relevant end use.
Contract terms can override default application
The clause applies unless the contract specifies otherwise. That means the contracting instrument may contain different instructions, but absent such language, the contractor is expected to follow the clause’s reduction and substitution approach.
Responsibilities
Contractor
Identify whether aerosol propellants or solvents used under the contract contain high global warming potential HFCs, consult EPA SNAP to find acceptable alternatives, and reduce use, release, or emissions of those HFCs when feasible. The contractor must weigh environmental, technical, and economic factors before selecting an alternative and should ensure the chosen substitute still meets performance, safety, and cost requirements.
Contracting Officer
Include the clause when prescribed and ensure the contract clearly states any deviations or special instructions if the agency intends different treatment. The contracting officer should also understand the SNAP-based requirement so the solicitation and contract align with the agency’s environmental objectives and the contractor’s compliance obligations.
Agency
Use the clause to implement federal environmental procurement policy for applicable aerosol-related acquisitions and maintain awareness of EPA SNAP updates that may affect acceptable alternatives. The agency should support acquisition planning so requirements, specifications, and evaluation criteria do not unintentionally force use of higher-GWP HFCs where lower-impact options are available.
Practical Implications
Contractors should check aerosol formulations early, not after award, because substitution decisions may affect product design, testing, safety approvals, and pricing.
A common pitfall is assuming any non-HFC substitute is automatically acceptable; the clause requires a feasibility analysis that includes performance, safety, and cost, not just environmental preference.
Another risk is relying on outdated SNAP information. Contractors and contracting officers should verify the current EPA SNAP list and supplemental tables before selecting or approving alternatives.
If a contract has unique technical requirements, the contractor should document why a lower-GWP alternative is not feasible, especially where flammability, toxicity, or performance concerns are involved.
For contracting officers, the practical effect is to encourage market research and specification writing that allows compliant alternatives rather than locking in legacy aerosol propellants or solvents.
Official Regulatory Text
As prescribed in 23.109 (d)(3) , insert the following clause: Aerosols (May 2024) (a) Definitions . As used in this clause– Global warming potential means how much a given mass of a chemical contributes to global warming over a given time period compared to the same mass of carbon dioxide. Carbon dioxide’s global warming potential is defined as 1.0. High global warming potential hydrofluorocarbons means any hydrofluorocarbons in a particular end use for which EPA’s Significant New Alternatives Policy (SNAP) program has identified other acceptable alternatives that have lower global warming potential. The SNAP list of alternatives is found at 40 CFR part 82 subpart G with supplemental tables of alternatives available at ( https://www.epa.gov/snap/ ). Hydrofluorocarbons means compounds that only contain hydrogen, fluorine, and carbon. (b) Unless otherwise specified in the contract, the Contractor shall reduce its use, release, or emissions of high global warming potential hydrofluorocarbons, when feasible, from aerosol propellants or solvents under this contract. When determining feasibility of using a particular alternative, the Contractor shall consider environmental, technical, and economic factors such as– (1) In-use emission rates, energy efficiency; (2) Safety, such as flammability or toxicity; (3) Ability to meet technical performance requirements; and (4) Commercial availability at a reasonable cost. (c) The Contractor shall refer to EPA's SNAP program to identify alternatives. The SNAP list of alternatives is found at 40 CFR part 82 subpart G with supplemental tables available at https://www.epa.gov/snap/ . (End of clause)