What can’t be sold on GSA Schedule is a question with a much longer answer than it had two years ago. Until 2025, the exclusion list was short: firearms, ammunition, construction work, and architect-engineer services. Then GSA launched its Rightsize initiative, retired dozens of Special Item Numbers (SINs), and moved whole product categories onto a formal out-of-scope list.
This guide covers every major exclusion, the reason behind it, and the narrow exceptions that still let some items through. It also shows how to check your own catalog before a contracting officer or auditor does it for you.
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Why GSA Out-of-Scope Items Matter More in 2026
The Multiple Award Schedule (MAS) remains the largest government commercial acquisition program in the world (gsa.gov). It closed FY2025 with $50.6 billion in sales across approximately 14,579 active contractors (GSA SSQ+, 2025). However, GSA is now actively shrinking both what the program carries and who holds it.
On March 24, 2025, GSA announced a plan to rightsize the MAS program. The plan lets underperforming contracts expire, targets non-compliance, cuts overlap with other buying channels, and drops low-demand items. As a result, the contractor base fell from 16,108 in FY2024 to approximately 14,579 in FY2025, roughly 1,500 contracts in one year (GSA SSQ+, 2025).
For you, the practical effect is simple. An out-of-scope item on a new offer draws a deficiency or a rejection. On an awarded contract, it becomes a compliance finding waiting to happen.
In addition, every Schedule sale now flows through monthly Transactional Data Reporting (TDR). TDR became mandatory on all SINs when Refresh 31 took effect on April 2, 2026 (gsa.gov). That gives GSA line-item visibility into exactly what you sell.
Before reviewing the list itself, it helps to understand the two tests GSA applies to every item.
Two Tests Decide What You Can Sell on a GSA Schedule
GSA schedule eligibility works at two levels, and every item has to pass both.
Most problems come from the second test, not the first. A company selling office furniture is squarely in scope, yet one chair line made in a non-designated country is not. For that reason, before you apply for a GSA Schedule, check both the category and every individual part number.
With those two tests in mind, here is what currently fails the category test.
GSA Out-of-Scope Items by Category
The table below lists the products and services GSA will not award, along with any narrow exception. Most entries come from Rightsize-era solicitation refreshes. They now appear as exclusion notes in each Large Category attachment of the MAS solicitation, published on SAM.gov.
| Excluded product or service | Exception, if any | Basis |
| Automotive parts | None | Rightsize |
| Books and publications | Technical publications and reports on SIN 511120 | Rightsize |
| Children’s toys, dolls, and games | None | Rightsize |
| Customizable awards, medals, and ribbons | None | Rightsize |
| Food, candy, and beverages | None. SIN 311423, Non-Perishable Foods, retired in Refresh 32 | Rightsize |
| Fully assembled fixed-wing aircraft | None | Rightsize |
| General clothing | Workwear, uniforms, and protective apparel on their designated SINs | Rightsize |
| Live animals for laboratory research | None | Rightsize |
| Musical instruments | None | Rightsize |
| Personal hygiene items | None | Rightsize |
| Promotional and imprintable products | None | Rightsize |
| Sporting goods | None | Rightsize |
| Swimming pool equipment and supplies | None | Rightsize |
| Firearms, live ammunition, explosives, and weapon components | Non-lethal training, safety, and marking ammunition | Statute |
| Foreign replica weapons and inert ordnance | None | GSA rule |
| Remanufactured, refurbished, or repaired products | Remanufactured toner | Rightsize |
| Products from non-TAA designated countries | Items substantially transformed in the U.S. or a designated country | Statute |
| Drones and unmanned aircraft systems | Models on the Blue UAS Cleared List | Statute |
| Construction and A&E services | Construction management and non-A&E engineering on SIN 541330ENG | Statute |
| Offerings tied to certain 2025 executive orders | Statutorily required offerings (climate-related exclusion only) | Executive order |
The promotional products exclusion catches more companies than they expect. It covers anything suited to engraving, imprinting, or customization. That reaches well beyond branded pens into mugs, drinkware, planners, portfolios, bags, and carrying cases.
Several of these exclusions need more explanation, because the exceptions are where most of the risk sits.
TAA Non-Compliant Products
TThe Trade Agreements Act of 1979 affects more catalogs than any other exclusion. It is implemented through FAR Subpart 25.4 and clause FAR 52.225-5. Every product on your Schedule must be made or substantially transformed in the U.S. or a TAA designated country.
China, India, Indonesia, Malaysia, Pakistan, and Russia are among the major manufacturing countries not on the designated list. Products made there cannot go on a Schedule, whatever the price or agency demand.
What substantial transformation means in practice
Substantial transformation means the product gained a new name, character, or use in the designated country. Simple assembly, repackaging, kitting, or relabeling rarely meets that bar. For close calls, U.S. Customs and Border Protection issues country-of-origin rulings. A CBP ruling is far stronger evidence than a supplier’s letter.
Where TAA compliance breaks down
TAA compliance is not a one-time check at award. If a manufacturer moves production to a non-designated country mid-contract, that product becomes non-compliant once the new stock ships. This is one of the most frequent problems we find in catalog reviews, because nothing on the product itself looks different.
Unsure where every product on your catalog is made?
Our Authorized Negotiators review country-of-origin documentation line by line and flag TAA gaps before GSA does.
Get Your Catalog Checked →Drones on GSA Schedule and the Blue UAS Exception
Drones and unmanned aircraft systems are out of scope for supply-chain security reasons. The American Security Drone Act of 2023 bars executive agencies from buying drones made or assembled by covered foreign entities. Its ban on operating those drones took effect on December 22, 2025.
The Act is implemented in FAR 52.240-1. In addition, Section 848 of the FY2020 National Defense Authorization Act places a separate restriction on defense buyers.
The one exception is drones on the Department of Defense’s Blue UAS Cleared List. Blue UAS clearance applies to a specific model and configuration, not to a brand. Consequently, a listed airframe paired with an unlisted camera or controller may not qualify. Match your catalog part numbers to the exact cleared configuration.
Remanufactured Products on GSA Schedule
GSA does not award remanufactured, refurbished, reconditioned, remarketed, or repaired products. Remanufactured toner cartridges are the only exception. Everything else on your Schedule must be new.
This rule tends to surprise resellers who carry refurbished stock alongside new inventory. Their commercial catalogs mix both conditions, so a bulk upload can pull refurbished SKUs onto the Schedule unnoticed. Whether you load products through the FAS Catalog Platform or through EDI catalog uploads, check a condition field before every submission.
Products are only half the picture. Some of the oldest exclusions apply to services.
Construction and A&E Services on GSA Schedule
Construction and architect-engineer (A&E) work are both excluded by statute, for different reasons. The Brooks Act (40 U.S.C. 1101 to 1104) requires agencies to select A&E firms on qualifications first and negotiate price afterward. MAS pricing works the other way, with rates negotiated up front and competition at the order level.
Construction falls under FAR Part 36 rather than the FAR Subpart 8.4 rules that govern Schedules. It also triggers Davis-Bacon prevailing wage determinations, which do not fit the Schedule’s fixed pricing model.
What construction-adjacent firms can still offer
The exclusion is narrower than many firms assume. Construction management services and engineering work outside the Brooks Act definition of A&E can still be offered under SIN 541330ENG. Facilities maintenance also remains in scope.
However, since Refresh 27, GSA no longer awards contracts to firms offering only standalone janitorial, plumbing, or electrical services. Those services now belong under Complete Facilities Maintenance.
If you run a construction or engineering firm, the real question is not whether you can hold a Schedule. Instead, it is which of your services fit, and how to describe them so the scope is clear to a contracting officer.
Executive Order Exclusions
A smaller group of exclusions comes from executive orders issued in 2025. The MAS solicitation now excludes offerings tied to diversity, equity, and inclusion programs, offerings that promote gender ideology, and paper straws.
Offerings built around the social cost of greenhouse gas emissions or environmental justice are also excluded, unless a statute requires them.
Executive order exclusions are the least permanent category. Still, they apply to every offer and modification GSA reviews today.
The GSA Rightsize Initiative and Retired SINs
Rightsizing works mostly through SIN retirements. When GSA retires a SIN, it removes that SIN from the solicitation and, through a mass modification, from awarded contracts.
A retired SIN does not always mean its products are out of scope. Some offerings moved to other active SINs. Others went straight onto the exclusion list. You need to know which happened to yours.
What to do when a SIN on your contract is retired
The simplest protection against all of this is a regular review of your own catalog.
How to Run a GSA Catalog Compliance Audit
A GSA catalog compliance audit catches out-of-scope items before they surface in TDR data or trigger an audit. Run one at least once a year and again after every solicitation refresh.
Out-of-scope items also cause trouble at the order stage. If an agency orders a product you cannot supply under the contract, you have to decline or correct the order. For that reason, a scope check belongs in your GSA order management routine as well.
Want a second set of eyes on your catalog?
We run catalog compliance reviews for GSA contractors and handle the deletion and SIN modifications that follow.
Request a Catalog Review →Where Contractors Get Out-of-Scope Rules Wrong
Quick Recap
Frequently Asked Questions
| Q Can I sell refurbished products on a GSA Schedule? |
| No. GSA does not award remanufactured, refurbished, reconditioned, or repaired items. Remanufactured toner cartridges are the only exception. |
| Q Can I sell products made in China on a GSA Schedule? |
| Only if they are substantially transformed in the U.S. or a TAA designated country. Final assembly or repackaging alone usually does not qualify. |
| Q Are drones completely banned from GSA Schedules? |
| No. Drones on the Blue UAS Cleared List can be offered. Drones made or assembled by covered foreign entities cannot be sold to executive agencies at all. |
| Q What happens if GSA retires my only SIN? |
| Your contract loses the vehicle for those sales. If your offerings fit another active SIN, add it by modification before the retirement takes effect. If not, those items leave the Schedule. |
| Q Can a construction company get a GSA Schedule? |
| Yes, for in-scope services. Construction management, non-A&E engineering, and complete facilities maintenance can qualify. General construction and Brooks Act A&E work cannot. |
The out-of-scope list has changed more since 2025 than in the decade before it, and each refresh can add to it. Checking your catalog now costs far less than defending it during an assessment. GSA Contract Services has helped companies obtain and maintain GSA Schedules since 1995, with more than 250 active clients and a team of Authorized Negotiators.
Is every item on your Schedule still in scope?
Talk with an Authorized Negotiator about your SINs, your catalog, and what the latest refresh means for your contract.
Confirm Your Scope →GSA Contract Services, LLC | 4622 Cedar Avenue, Suite 123, Wilmington, NC 28403 | 202-280-7060 | Sales@GSA-CS.com
