What counts as Canadian content in procurement, and what should suppliers show?

The federal Buy Canadian Policy

The Buy Canadian Policy took effect on December 16, 2025. It includes a framework, a policy on Canadian materials in major construction and defence projects, a policy on Canadian suppliers and Canadian content in strategic procurements, and a policy on reciprocal procurement.

The Canadian suppliers and content policy applies to competitive strategic procurements of $25 million and up published from December 16, 2025, and $5 million and up published from June 15, 2026. Departments are encouraged to apply it below those thresholds too.

How the federal policy defines the terms

Canadian supplier: a business with a permanent, named place of business in Canada, registered and filing taxes in Canada, with staff or day-to-day operations here, and not subcontracting in a way that leaves minimal value added in Canada.

Canadian good: a good wholly manufactured or originating in Canada, or one with imported components that has changed enough in Canada to meet the CUSMA rules of origin, read as applying to Canada alone.

Canadian content: Canadian value added, which for goods includes the value of the portion produced in Canada and costs incurred here for things like research and development, customization, installation, warehousing and after-sales service.

The contracting authority must give a supplier the chance to submit evidence and must document its decision.

This is a different test from a label

A “Made in Canada” label is assessed against the Competition Bureau's 51% direct-cost threshold. A “Canadian good” in federal procurement is assessed against CUSMA rules of origin. A product can meet one test and not the other, so do not assume a label answers a procurement question.

What suppliers should keep ready

Proof of a permanent place of business and tax registration in Canada.

A bill of materials showing where each significant input comes from, with supplier invoices or origin declarations.

A description of the manufacturing steps done in Canada, and a cost breakdown of Canadian and imported direct costs.

Any dated, independent review of a product line's Canadian content, clearly labelled as supporting evidence.

Provincial, municipal and private buyers

Other buyers set their own definitions. Ask for the definition and the evidence they accept in writing before you bid.

Where a Checked Canadian check fits

A check is a dated review of one product line's direct-cost share and place of last substantial transformation against the Competition Bureau's thresholds. It does not certify, qualify or satisfy the Buy Canadian Policy or any other procurement rule. It is supporting evidence a buyer can weigh alongside everything else. How a check works.