Contractors reviewing the latest update to the Multiple Award Schedule (MAS) Solicitation under Refresh #23 will notice that many of the changes are technical updates regarding templates and modification guides. Some of the most notable updates include revised instructions for several Special Item Numbers (SINs) and edits to sample cover letters available on the available offerings for modification and mass modification guidance page.
One significant change under this Refresh is the introduction of the clause 552.238-118 Single-use Plastic (SUP) Free Packaging Identification. This new provision helps agencies identify contractors who offer products that utilize SUP-free packaging in the MAS program. The goal of this provision is to encourage contractors to participate in ongoing efforts to phase out unnecessary materials deemed harmful to the environment. More on that a bit later in this blog post! Let’s proceed to discuss what the SUP Packaging rule is, what it’s not, and how it may affect you as a contractor.
SUP-Free Packaging Rule
The announcement of this rule was introduced back in Q2 2024 as a step forward in advancing President Biden’s Federal Sustainability Plan. This new rule is designed to help and empower agencies to take action by reducing and phasing out the purchase of single-use plastic products.
You’re probably curious about what this means for contractors in terms of their product and shipping packaging practices. Please understand that GSA is not requiring or forcing contractors to use sustainable packaging. This is not a ban on Single-Use plastic. Rather, it simply asks contractors to indicate if they offer products with SUP-free packaging and whether that packaging comes as the default option.
Single-Use Plastic (SUP) Packaging Examples
Under Subpart 502.1 of the GSAR, SUP-free packaging materials are used for product or shipping materials that do not contain single-use plastics. Common examples of single-use plastics found in shipping and product packaging include non-biodegradable materials like packing peanuts (which are often made from non-recyclable foam), wrapping materials, molded plastics, bubble wrap, and other plastic cushioning items that are typically discarded after the shipment has been opened. As these materials don’t easily decompose and are not always recyclable, GSA recognizes that they pose long-term waste challenges to the environment, especially if these materials are found in large quantities/volumes of shipments.
Introducing the Sup-Free Icon on GSA Advantage
Through the implementation of SUP-free packaging, the goal, as expected, is to have an anticipated market shift of companies reducing single-use plastic. GSA will soon be introducing a new icon on GSA Advantage to make sustainable choices easier for agencies to identify and make purchases while meeting their plastic waste reduction goals.
This icon will highlight contractors that provide SUP-free packaging and encourage federal agencies to prioritize these options when they are making their purchasing decisions.
Adding the SUP-Free Icon for New/Incoming Offerors
Offerors proposing products with single-use plastic (SUP) free packaging must complete the GSAR provision 552.238-118, titled "Single-Use Plastic (SUP) Free Packaging Identification (July 2024)," in the eOffer application. If there are any costs or savings associated with SUP-free packaging has to be reflected in the proposed product price.
Once your MAS contract is awarded, you can add the icon for SUP-free packaging to your products on GSA Advantage. If you are using the Scheduled Input Program (SIP), locate the product or accessories input screen. Within that field, access the Product Environmental/Special Features screen, where you can select "Single Use Plastic (SUP) Free Packaging" under option 2.
If you are utilizing the IMSG import file, make sure that you use the code "SU" to identify SUP-free products. For those using Electronic Data Interchange (EDI), include the environmental/special feature code "SU" in your catalog file.
Adding the SUP-Free Icon for Existing MAS Contracts
Following the acceptance of Refresh #23, SUP-free availability will be incorporated. However, if you decide to highlight products on GSA Advantage with the SUP-free packaging icon, you’ll need to submit a Terms and Conditions modification request in eMod. The mod will have you “mark off” portions deemed applicable to your SUP-free brand packaging and SUP-free shipping packaging as shown below.
You can find and download a word version of the 552.238-118 provision on the Roadmap page of Required templates for a MAS offer.
If you are using the FAS Catalog Platform (FCP) as an alternative to SIP, you’ll be required to submit a Product Descriptive Change Modification along with the Terms and Conditions Modification to add the provision in eMod. You’ll also be required to complete an associated Change Action in FCP where you’ll need to input the code “SU” to the product info code field and complete the modification. If you operate as an EDI user, be sure that you view the SIP instructions as mentioned above.
Is the SUP-Free Icon the Right Fit for Your Products?
If you’re considering whether the new SUP-free icon is a suitable choice for your products, it’s important to understand that while this update highlights your commitment to helping federal agencies achieve their environmental goals, it also requires some effort on your part. Read through the new solicitation clause to make sure that your company can provide SUP-free shipping practices.
As mentioned, your contract will need to undergo a SIP upload submission for approval. Make sure before you proceed with your terms and conditions modification that you conduct an internal review of your product offerings. As you review your listings on GSA Advantage, you may discover additional tasks that need to be completed. This can be in the form of price updates, description changes, or even deletions. Please ensure that all necessary contract modifications are completed through approval prior to completing your SIP upload.
For more information regarding SUP-free packaging or anything related to GSA latest release of Refresh #23, please reach out to one of our consultants as we would be happy to assist you further!
