Demonstrate U.S. Procurement Restriction Policy Compliance: eShop Requisitions

1. Step 1: Navigate to the Correct Means of Procurement
2. Step 2: Locate the U.S. Procurement Restriction Policy Questions
   1. Cheque Requisition Form
   2. Purchase Requisition Form
3. Step 3: Answer the U.S. Procurement Restriction Policy Questions
   1. Question 1: Is this a U.S. Business, as defined by the U.S. Procurement Restriction Policy?
   2. Question 2: How did you comply with the U.S. Procurement Restriction Policy in making your purchase decision?

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:

1. engage in Competitive Procurement (ex: receiving competing quotations or engaging in Open Competitive procurement where required by the Procurement Policy), or
2. comply with the Building Ontario Businesses Initiative Act (BOBIA)

When completing a Cheque Requisition or Purchase Requisition in eShop, you will be asked to demonstrate your compliance with the U.S. Procurement Restriction Policy by answering two mandatory questions.

Questions? Email us at ProcurementServices@carleton.ca.

Step 1: Navigate to the Correct Means of Procurement

The means of procurement available to you is based on the Total Procurement Value of your purchase. This page focuses on eShop requisition forms only – if your means of procurement is eCard, Corporate Card (PCard), Travel and Expense System, or eShop Catalogues (Convenience Vendors), please see “How to Demonstrate Compliance” for more information.

Step 2: Locate the U.S. Procurement Restriction Policy Questions

Cheque Requisition Form

Within the Cheque Requisition form, find the “U.S. Procurement Restriction Policy” header above the Vendor Information section.

Important: 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.

Purchase Requisition Form

Within the Purchase Requisition form, find the “U.S. Procurement Restriction Policy” header under the Competitive Bid Requirements section.

Step 3: Answer the U.S. Procurement Restriction Policy Questions

You will be required to answer both U.S. Procurement Restriction Policy questions with respect to the Vendor you are procuring goods or services from.

Question 1: Is this a U.S. Business, as defined by the U.S. Procurement Restriction Policy?

The university may rely on a representation by the Vendor regarding their status as a U.S. Business as defined by the provincial policy. Even where the status of the Vendor may appear obvious, Procurement Services encourages you to seek the appropriate representation.

To determine the answer to Question 1:

Answer Option	Select this Answer if
Yes	Your Vendor represented they are a U.S. Business using the Business Representation form.
No	The Vendor has a  in eShop, indicating they have represented their status as a non-U.S. Business. Your Vendor represented they not a U.S. Business using the Business Representation form.
Procurement was completed before April 4, 2025.	You are using a currently valid eShop Contract Reference Number as your Competitive Bid Requirement. HINT: did you know that eShop has a “Contracts” module you can search using the Contract Reference Number provided to you upon Contract execution? Look for the  icon in the eShop menu bar. Answer option available on Purchase Requisition form only.

Remember, if your Vendor doesn’t have the non-U.S. Business symbol that may mean they haven’t had the opportunity to represent their status yet and does not necessarily confirm they are a U.S. Business.

Question 2: How did you comply with the U.S. Procurement Restriction Policy in making your purchase decision?

The U.S. Procurement Restriction Policy requires you to purchase from a non-U.S. Business unless a valid exemption is approved.

To determining the answer to Question 2:

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