President Trump signed a Presidential Memorandum on September 16, 2026, directing federal officials to identify Canadian-origin items in the federal civil procurement system that could be removed or made unavailable for purchase. The memorandum does not name specific products or impose an immediate ban, but it opens a review process that companies supplying Canadian-origin goods into the federal market should be tracking now.
What the Memorandum Does
Titled “Restoring Reciprocity in Government Procurement,” the memorandum directs the Director of the Office of Management and Budget (OMB) and the U.S. Trade Representative (USTR), coordinating with the Federal Acquisition Regulatory (FAR) Council, to identify and take all steps permitted by applicable law to remove or make non-available for purchase Canadian-origin items in the federal civil procurement system, where warranted.
OMB is separately directed to notify relevant agencies of domestic alternatives to affected Canadian-origin items, to the extent permitted by law. Agency heads are authorized to take appropriate measures within their own authority to implement the memorandum, and may redelegate that authority internally.
The memorandum applies specifically to the federal civil procurement system, which the administration ties to more than $280 billion in annual procurement covered under the WTO Agreement on Government Procurement.
Reciprocal Monitoring, Not a One-Way Action
The memorandum also directs USTR to continue monitoring Canada’s treatment of U.S.-origin goods in Canadian federal and provincial procurement markets. USTR is instructed to inform the President of circumstances that might warrant further action, as well as circumstances that might warrant restoring a Canadian-origin item’s availability for federal procurement, such as a change in Canadian policy.
The stated basis for the action is Canada’s “Buy Canadian” policy and related provincial preferences for Canadian products and content, which the administration characterizes as unreasonable barriers to U.S. companies seeking access to Canadian government procurement markets.
Builds on an Earlier GSA Directive
This memorandum follows a September 8, 2026 directive from President Trump to the General Services Administration (GSA) to remove Canadian-origin products from its Multiple Award Schedules, a government-wide contracting program covering more than $50 billion in federal procurement. That earlier directive gave agencies access to Canadian-origin commercial products and services through negotiated, pre-set pricing; removal from the schedules would cut off that specific purchasing channel.
Both actions follow the September 8 escalation of Section 338 tariffs and import restrictions on Canadian goods, and are part of the broader deterioration in U.S.-Canada trade relations this year.
What the Memorandum Does Not Do
The memorandum does not itself identify which Canadian-origin items will be affected, does not impose an immediate purchasing ban, and applies only “to the extent appropriate and consistent with law.” It expressly does not create any enforceable right or benefit for any party, and its implementation is subject to available appropriations.
Actual removal of specific items from procurement will depend on the OMB/USTR review, coordination with the FAR Council, and implementation by individual agencies, which may proceed on different timelines.
Who Should Be Watching This
This affects more than direct government contractors. Companies that supply Canadian-origin goods anywhere in a federal contractor’s supply chain, including subcontractors and component suppliers, could see demand shift if their products are identified and removed from procurement channels.
Trade compliance and government-contracts teams should coordinate now, since country-of-origin determinations that matter for customs purposes are the same determinations that will matter for this review.
What Companies Supplying the Federal Market Should Do Now
- Identify Canadian-origin products and components in your own supply chain that ultimately reach federal government buyers, directly or through a contractor.
- Review GSA Multiple Award Schedule listings and other federal contract vehicles for Canadian-origin items that could be affected.
- Monitor FAR Council rulemaking and agency-specific guidance implementing the memorandum.
- Identify potential domestic or third-country alternative sourcing in case Canadian-origin items become unavailable for federal sales.
- Confirm country-of-origin documentation is current and consistent across both customs and government-contracts purposes.
- Watch for OMB notices identifying domestic alternatives, which may signal which product categories are under active review.
References
- Presidential Memorandum: Restoring Reciprocity in Government Procurement (WhiteHouse.gov, Sept. 16, 2026)
- Fact Sheet: President Donald J. Trump Restores Reciprocity in Government Procurement (WhiteHouse.gov)
- Fact Sheet: President Donald J. Trump Responds to Canada’s Retaliation (Sept. 8, 2026)
Contact the Alba team for assistance reviewing country-of-origin documentation and potential exposure in the federal procurement supply chain.
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