- What is a U.S. Business?
- How to Comply with the U.S. Procurement Restriction Policy
- How to Demonstrate Compliance
- U.S. Procurement Restriction Policy Resources
- Frequently Asked Questions
Effective April 4, 2025, the province of Ontario announced a U.S. Procurement Restriction Policy that limits the university’s ability to engage with U.S. businesses for the purchase of goods or services. The Procurement Restriction Policy applies to Carleton as a Broader Public Sector institution, and the university will be required to demonstrate compliance with our obligations under the policy by submitting a report on its procurement activity via Procurement Services.
The U.S. Procurement Restriction Policy does not override the university’s requirements to:
- engage in Competitive Procurement (ex: receiving competing quotations or engaging in Open Competitive procurement where required by the Procurement Policy), or
- comply with the Building Ontario Businesses Initiative Act (BOBIA)
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Questions? Email us at ProcurementServices@carleton.ca.
What is a U.S. Business?
A U.S. Business is defined as any company that:
- Has its headquarters or main office in the United States, AND
- Has fewer than 250 full-time employees in Canada.
The university may rely on a representation by the Vendor regarding their status as a U.S. Business as defined by the provincial policy. HINT: Vendors that have previously represented their status will be indicated in eShop (
for Ontario Business, 
for Non-U.S. Business).
How to Comply with the U.S. Procurement Restriction Policy
The U.S. Procurement Restriction Policy limits the university from procuring goods and/or services from U.S. Businesses.
If you don’t know whether your Vendor is a non-U.S. Business (look for the in eShop), you may choose to have them complete an Business Representation form (must be logged onto the VPN). Remember, if your Vendor doesn’t have the symbol that may mean they haven’t had the opportunity to represent their status yet and does not necessarily confirm they are not a Non-U.S. Business.
Exemption Criteria
Procurements must be made from a non-U.S. Business unless a valid exemption is approved. Purchases from U.S. Businesses are permitted only if:
- The Vendor is the only viable source for the good or service being purchased, AND
- The procurement of that good or service cannot be delayed.
If an exemption applies to your procurement, demonstrate the exemption as required by your means of procurement. This exemption is a separate consideration from the Limited Tendering Exceptions associated with Competitive Procurement.
How to Demonstrate Compliance
Demonstrate your compliance with the U.S. Procurement Restriction Policy when making your actual purchase. There are different expectations for demonstrating compliance depending on your means of procurement (i.e. how you are making your purchase).
| Means of Procurement | Demonstrate Compliance |
| eCard | All on-campus Vendors comply with the U.S. Procurement Restriction Policy. |
| Corporate Card (Pcard) (up to $10,000.00) | If you purchase a good or service from a U.S. Business, keep the justification for that decision in your records. |
| Travel and Expense System | If you purchase a good or service from a U.S. Business, keep the justification for that decision in your records. |
| eShop Catalogues | Look for one of the following symbols in eShop:
|
| eShop Cheque Requisition* | Complete the U.S. Procurement Restriction Policy questions included in the Cheque Requisition form. If applicable, complete and attach your U.S. Business Justification form. |
| eShop Purchase Requisition | Complete the U.S. Procurement Restriction Policy questions included in the Purchase Requisition form. If applicable, complete and attach your U.S. Business Justification form. |
the *With some exceptions, a Cheque Requisition form can be used to request payment to a Vendor for Non-competitive procurements only. Please do not use this form if a Purchase Requisition form has already been processed, or the payment is for personal reimbursement of business expenses.
U.S. Procurement Restriction Policy Resources
Templates
Note that you must be logged onto the VPN to access the following forms, even if you are on campus. For a full explanation of how to use these forms, see above.
Frequently Asked Questions
Procurement Services is committed to supporting your compliance efforts by sharing tools, templates and indicating which Vendors have represented that they are non-U.S. Businesses in eShop as requisitions are submitted. Don’t see your question? Have a suggestion? Email us at ProcurementServices@carleton.ca.