A GSA Schedule Can Be Valuable — Unless You Sell This

A GSA Schedule can be an extremely valuable contract, unless you sell certain products and services deemed “Out-of-Scope Items.”

The GSA Multiple Award Schedule (MAS) Contract, frequently referred to as the GSA Schedule, is a governmentwide contract that streamlines the procurement process and helps open the door to federal contract opportunities.

While the GSA Schedule is the largest federal contract in terms of both dollar value and the breadth of offerings, there are specific products and services that cannot be sold under the contract. In fact, GSA has been tightening the boundaries of the Schedule program over time and there’s a growing list of products and services that are ineligible under the contract.

What’s Not Allowed on the GSA Schedule?

Quick answer: Companies cannot receive a GSA Schedule Contract for certain products and services, including construction, architecture and engineering services, firearms, ammunition, weapon components, automotive parts, food and drinks, sporting goods, and remanufactured items (except toner).

Additionally, offerings that conflict with 2025 Executive Orders covering gender ideology, climate-related provisions, and DEI programs are also prohibited. All of these products and services are considered out of scope, meaning they cannot be awarded on a GSA Schedule Contract. View the full list here.

• Understanding GSA Schedule Out-of-Scope Items
• What Products and Services Cannot be Sold Under the GSA Schedule Contract?
• Out-of-Scope Offerings Based on Statute
  • Why Aren’t A&E Services Allowed on the GSA Schedule?
  • Why Isn’t Construction Work Allowed on the GSA Schedule?
  • Why Aren’t Drones Allowed on the GSA Schedule?
  • Why Aren’t Products Made in a Non-TAA Designated Country Allowed on the GSA Schedule?
  • Why Aren’t Firearms & Ammunition Allowed on the GSA Schedule?
• Out-of-Scope Offerings Based on Rightsize
• Out-of-Scope Offerings Based on Executive Orders
• What Should GSA Contractors Do About Out-of-Scope Items?

Understanding GSA Schedule Out-of-Scope Items

The GSA Schedule Contract covers millions of products and services organized under 12 Large Categories and roughly 300 Special Item Numbers (SINs), spanning everything from IT, professional services, and security, to furniture and industrial products. To qualify for a GSA Schedule contract, your offerings must fit under one or more SINs, which provides more specific descriptions under each Large Category.

As we mentioned previously, the GSA Schedule has the widest range of product and service offerings of any federal contract. That said, the scope of what can be sold under the GSA Schedule has been narrowing over time and has accelerated in recent years.

You could argue that the GSA MAS Consolidation in fiscal year 2020 marked the start of decreasing the breadth of GSA Schedule eligible products and services. The GSA MAS Consolidation involved merging 24 individual GSA Schedules into the single Multiple Award Schedule (MAS) used today. During that process, GSA reduced more than 900 SINs down to roughly 300. As a result of that consolidation, some products and services no longer had a clear fit under the program.

While the scope of GSA Schedule offerings narrowed slightly post-Consolidation, up until recent years, the list of products and services that could not be sold under the GSA Schedule was fairly short. With the exception of firearms and ammunition, the exclusion list consisted mainly of offerings that were not allowed due to statute. That changed in 2025 with the launch of GSA’s Rightsize initiative.

With a few exceptions, offerings that are not allowed under the GSA Schedule largely fall within three categories:

1. Statute-Driven Out-of-Scope Offerings
2. Rightsize-Driven Out-of-Scope Offerings
3. Executive Order-Driven Out-of-Scope Offerings

What Products and Services Cannot be Sold on the GSA Schedule Contract?

GSA will not award products or services that fall under the categories listed in the chart below. The GSA Schedule Out-of-Scope Products & Services Chart also notes if there are any exceptions to the exclusion, as well as the driving force behind the exclusion.

The driving force is important because it indicates the likelihood of any future change. It is highly unlikely that exclusions based on statute will change.

While exclusions based on GSA’s Rightsize Initiative could change, this is unlikely absent a significant shift in market demand or agency policy priorities.

On the opposite end of the spectrum, exclusions based on Executive Orders have the lowest level of permanence. EO driven exclusions could be struck down through a court challenge or cancelled at any time by a future President.

GSA Schedule Out-of-Scope Products & Services Chart

Out-of-Scope Offerings Based on Statute

Why Aren’t A&E Services Allowed on the GSA Schedule?

The Brooks Architect-Engineers Act (40 U.S.C. §§ 1101–1104) requires architecture and engineering (A&E) firms to be selected based on qualifications first, with price negotiated afterward. That selection method conflicts with how the MAS program works — GSA MAS pricing is negotiated up front and offerings compete primarily on price at the order level. Because of this incompatibility, A&E services governed by the Brooks Act have never fit under the GSA Schedule.

Why Isn’t Construction Work Allowed on the GSA Schedule?

Construction work is also excluded from the GSA Schedule, but for a different reason than A&E services. Construction and general contracting fall under FAR Part 36, not the FAR Part 8.4 authority that governs the Schedules program, and it triggers the Davis-Bacon Act (40 U.S.C. § 3141). Davis-Bacon requires contracts over $2,000 for the construction, alteration, or repair of public buildings or public works to pay laborers and mechanics no less than locally determined prevailing wage rates. The wage-determination requirement doesn’t fit the Schedule’s negotiated, fixed-pricing structure.

Why Aren’t Drones Allowed on the GSA Schedule?

Drones and Unmanned Aircraft Systems (UAS) are excluded from the GSA Schedule for national security and supply chain reasons rather than a single agency-jurisdiction rule.

The prohibition is anchored in statute:

• The American Security Drone Act of 2023 bars executive agencies from procuring — and, as of December 22, 2025, operating — UAS manufactured or assembled by a covered foreign entity,
• Section 848 of the FY2020 National Defense Authorization Act separately bans drones and components made in covered foreign countries (most notably China).

These requirements are implemented through the FAR (see FAR clause 52.240-1) and reinforced by Executive Order 13981 and GSA’s own security policy, which cite risks such as surveillance, data theft, and disruption of federal information networks. Because the core prohibition rests on statute and an implementing FAR clause rather than solely on an Executive Order, it sits toward the durable end of the exclusion spectrum.

The one exception is drones vetted through the Department of Defense Defense Innovation Unit’s (DIU) Blue sUAS Program — those on the Blue UAS Cleared List may still be offered on the Schedule.

Why Aren’t Products Made in a Non-TAA Designated Country Allowed on the GSA Schedule?

You cannot sell products that were manufactured in a non-TAA designated country on the GSA Schedule due to the Trade Agreements Act.

The Trade Agreements Act (TAA) of 1979, implemented through FAR Subpart 25.4 and incorporated into MAS contracts via FAR clause 52.225-5, requires that products sold on a GSA Schedule be either U.S.-made or manufactured (or “substantially transformed”) in a TAA-designated country.

Notable non-designated countries — meaning products from these countries generally cannot be sold on a GSA Schedule — include China, Russia, India, Indonesia, Iran, Iraq, Malaysia, and Pakistan. It is also worth noting that compliance isn’t a one-time check. If a manufacturer shifts sourcing to a non-designated country during the contract term, the affected product becomes non-compliant and must come off the Schedule, even if it was compliant at award.

For the full list of TAA-designated countries and how “substantial transformation” is determined, see our TAA Designated Countries guide.

Why Aren’t Firearms & Ammunition Allowed on the GSA Schedule?

As noted in the exclusion chart, firearms and ammunition are not allowed on the GSA Schedule. This exclusion is not new. Firearms and ammunition have been off-limits since well before GSA began including a formal notice in each Large Category attachment defining the ban.

The driving force behind this exclusion is based on a combination of statute and procurement authority, which rests with the Department of Defense versus GSA.

The key authorities behind this exclusion include:

• Defense Logistics Agency (DLA) authority — 10 U.S.C. § 193 designates DLA as a combat support agency and DoD’s common-supply agency, placing responsibility for firearms and related items within the DoD supply system rather than GSA.
• Single Manager for Conventional Ammunition — DoD Directive 5160.65 designates the Secretary of the Army as DoD’s single manager for conventional ammunition, and Section 806 of the Strom Thurmond National Defense Authorization Act for Fiscal Year 1999 (Public Law 105-261) authorizes the single manager to restrict ammunition procurement to the national technology and industrial base.
• Small Arms Procurement Authority — the Army is designated the single procuring agent for small arms across DoD and maintains the central registry of DoD small arms serial numbers.
• More Broadly, the Gun Control Act of 1968 (18 U.S.C. Ch. 44) — independently regulates the manufacture, sale, and interstate commerce of firearms and prohibits the purchase of foreign military surplus weapons.

GSA Schedule Firearms & Ammunition Full Exclusions

Out-of-Scope Offerings Based on Rightsize

GSA’s Rightsize Initiative Downsizes MAS Offerings

The short out-of-scope list that held for years (firearms and ammunition, Brooks Act A&E services, and Davis-Bacon construction work) changed significantly starting in 2025.

GSA announced the initiative to “rightsize” the MAS Program in March of 2025. The Federal Acquisition Service (FAS) Commissioner at the time framed rightsizing the MAS Program as “a significant opportunity” to “prioritize value and fiscal responsibility in contracting”, tying the effort to the broader administration-wide push to cut waste and improve government operations.

A large component of the Rightsize campaign involves implementing existing policies such as allowing contracts that fail to meet sales thresholds to expire, addressing contractor non-compliance, and reducing redundancies with other procurement channels.

Another key aspect of the rightsizing initiative involves “eliminating items with insufficient market demand or where administrative costs outweigh procurement benefits.” This resulted in the retirement of numerous SINs, and moving most of the offerings under those retired SINs to a formal “Out-of-Scope” list published in each Large Category attachment. Since 2025, GSA has retired more than 40 SINs through a series of Solicitation Refreshes:

Not every retired SIN’s offerings became out of scope — some were folded into other existing SINs. But many landed on the expanding Out-of-Scope list, which is where most of the product categories below come from. Refresh 32, for example, retired SIN 311423 (Non-Perishable Foods), which is reflected in the exclusion table below by “food, candy, and drinks”.

Out-of-Scope Offerings Based on Executive Orders

Beyond statute driven and Rightsize driven exclusions, the GSA Schedule solicitation now explicitly excludes offerings that conflict with a series of Executive Orders issued in 2025. These exclusions are policy-driven rather than product-driven. As noted previously, Executive Order-based exclusions have the highest likelihood of being subject to change. This is particularly true of EOs tied to a specific administration’s priorities, as well as EOs under legal challenge.

If your company offers services that fall under the Executive Order exclusions in the chart below, consider reviewing how your offerings are scoped and described. The statutory-authority caveat in particular means the line between “excluded” and “still in scope” can come down to how an offering is grounded — not just what it’s called.

What Should GSA Contractors Do About Out-of-Scope Items?

Whether you’re an existing or prospective GSA Schedule contractor, here are a few tips for addressing and remaining compliant with Out-of-Scope Items:

• Audit your catalog. Cross-reference your awarded products and services against the out-of-scope categories above. If an item appears without a matching exception, it doesn’t belong on your contract — and leaving it there creates compliance risk.
• Check the exceptions carefully. Several exclusions come with narrow carve-outs tied to specific SINs (remanufactured toner, technical publications under SIN 511120, workwear and protective apparel under their designated SINs). If your offering fits an exception, make sure it’s awarded under the correct SIN.
• Don’t try to force a fit. If a product or service is out of scope, repackaging or relabeling it won’t change that — and it can create bigger problems during an assessment or audit than simply keeping it off the contract in the first place.
• Monitor MAS Refreshes. The out-of-scope list has changed more in the past two years than in the decade before it, largely driven by GSA’s ongoing Rightsize initiative. Staying up to date on GSA MAS Refreshes is the most reliable way to catch new exclusions.

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Questions About Whether Your Offerings Are in Scope?

Scope questions aren’t always a black-and-white distinction. They frequently fall into a gray area, especially where Rightsize-driven SIN retirements, Executive Order exclusions, and SIN-specific exceptions are all in play.

However, it’s worth keeping this list in perspective. Despite these exclusions, there are still millions of products and services that remain eligible for a GSA Schedule Contract, and in demand. The out-of-scope list is narrow relative to the full breadth of what the GSA Schedule program still covers.

Whether you’re unsure if your offerings are considered out-of-scope, or you’d like to discuss if a GSA Schedule Contract is the right fit for your company, our team can help.

Contact us today for a complimentary consultation.