President directs federal agencies to remove Canadian origin items from federal civil procurement
As of our last check on November 3, 2026, this has been signed by the President. It may need agency action before it affects employers.
We check the Federal Register daily for later actions. We check federal court opinions for rulings on published rules weekly, on Mondays. A ruling can take time to reach us, so not finding one here does not mean there is none.
In short
- What changed
- The President directed the Office of Management and Budget (OMB) and the United States Trade Representative to find Canadian origin items in federal civil procurement that can be removed or made unavailable for purchase. It also directed agency heads to take measures to carry out the memorandum. The stated reason is Canada's "Buy Canadian" preferences.
- Who's affected
- The memorandum is addressed to federal officials, not employers. Businesses that sell Canadian origin items to federal civil agencies could be affected once agencies act.
- What to do
- There are no new or changed duties for employers, and no HR or payroll action is needed. Federal suppliers that offer Canadian origin products may want to watch for agency steps on those items.
What changed
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From the sourceSec. 2(a)
identify and take all steps permitted by applicable law with respect to Canadian origin items in the Federal civil procurement system that can, where warranted, be removed or made non-available for purchase
The memorandum directs the Director of the Office of Management and Budget (OMB) and the United States Trade Representative, working with the Federal Acquisition Regulatory Council, to identify and take the steps the law allows on Canadian origin items in the federal civil procurement system that can be removed or made non-available for purchase.
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From the sourceSec. 2(a)
take appropriate steps to notify relevant executive departments and agencies (agencies), as determined by the Director, of domestic alternatives to Canadian origin items
The OMB Director is to notify relevant agencies of domestic alternatives to Canadian origin items.
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From the sourceSec. 2(d)
The head of each agency is authorized to and shall take all appropriate measures within the agency's authority to implement this memorandum.
The head of each agency is directed to take all appropriate measures within the agency's authority to carry out the memorandum.
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From the sourceSec. 2(c)
might warrant restoring a Canadian origin item's availability for Federal civil procurement, such as a change in policy by the Canadian government
The Trade Representative is to keep monitoring Canada's treatment of United States origin items and report circumstances that might call for further action or for restoring a Canadian origin item's availability.
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From the sourceSec. 1. Purpose and Policy
Canadian companies continue to have preferential access to the United States Government procurement system.
The stated reason is that Canada has set preferences for Canadian products under its "Buy Canadian" policy while Canadian companies keep preferential access to United States government procurement.
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From the sourceSec. 3(b)
This memorandum shall be implemented consistent with applicable law and subject to the availability of appropriations.
Also: Sec. 3(c)
This memorandum is not intended to, and does not, create any right or benefit
The memorandum is to be carried out consistent with applicable law and subject to available funding, and it creates no right or benefit enforceable at law.
Who is affected
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From the sourceAddressees
Memorandum for the Secretary of War[,] the United States Trade Representative[,] the Director of the Office of Management and Budget[,] the Administrator for Federal Procurement Policy[,] the Administrator of General Services
The memorandum is addressed to federal officials, including the OMB Director, the Trade Representative, the Administrator for Federal Procurement Policy and the Administrator of General Services.
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Our analysisSec. 2(a)
Canadian origin items in the Federal civil procurement system that can, where warranted, be removed or made non-available for purchase
Businesses that sell Canadian origin items to federal civil agencies could lose those sales if agencies remove the items or make them unavailable for purchase.
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Our analysisSec. 2. Removing Canadian Origin Items From the Federal Procurement System
Removing Canadian Origin Items From the Federal Procurement System
The memorandum deals with what the government buys. It says nothing about wages, benefits, hiring or other employment terms, so it does not directly affect HR or payroll work.
What it means in practice
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Our analysisSec. 2(a)
of domestic alternatives to Canadian origin items, to the extent permitted by law
Federal suppliers may face more emphasis on domestic alternatives, because the OMB Director is to point agencies to domestic alternatives to Canadian origin items.
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Our analysisSec. 2(d)
shall take all appropriate measures within the agency's authority to implement this memorandum
Any change for suppliers depends on later agency measures, which the memorandum does not describe or schedule.
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Our analysisSec. 2(c)
such as a change in policy by the Canadian government that would end the current treatment toward United States origin items
The restriction could be reversed for an item if Canada changes its policy, since the Trade Representative is to report circumstances that might warrant restoring availability.
What to do
Required
There is no employer obligation yet. The memorandum directs federal officials to act. Watch for steps by OMB, the Trade Representative, the Federal Acquisition Regulatory Council and individual agencies to remove Canadian origin items from federal civil procurement or make them unavailable.
Worth considering
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Our suggestionSec. 2(a)
notify relevant executive departments and agencies (agencies), as determined by the Director, of domestic alternatives to Canadian origin items
If you sell goods to federal civil agencies, consider identifying which of your products are Canadian origin items and whether you can offer domestic alternatives.
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Our suggestionSec. 2(d)
The head of each agency is authorized to and shall take all appropriate measures within the agency's authority to implement this memorandum.
Consider having your government contracts or compliance team watch for agency measures that carry out the memorandum.
Open questions
The source leaves these open. We'll update this record if a later document answers them.
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Which Canadian origin items will be removed from federal civil procurement or made unavailable, and when?
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How will an item be judged to be of Canadian origin?
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Will the measures affect existing federal contracts or only future purchases?
History
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Restoring Reciprocity in Government Procurement Source (opens in a new tab)