As reported on the freebsd-security mailing list the EFI loader components are identified by freebsd-update builds as having changed on every build. This is due to timestamps embedded in the PE/COFF headers in the EFI files.
Use SOURCE_DATE_EPOCH to set the timestamps to a known value, arbitrarily chosen as Fri 1 Jan 2016 00:00:00 UTC.
[1] https://lists.freebsd.org/pipermail/freebsd-security/2016-August/009037.html