President Trump signed a presidential memorandum titled “Restoring Reciprocity in Government Procurement” on September 16, 2026. The memorandum directs federal officials to take steps to restrict certain Canadian-origin products from the federal civilian procurement system. The action responds to Canada’s “Buy Canadian” policies, which prioritize Canadian suppliers and goods in government procurement. The memorandum aligns with the administration’s broader procurement and trade reforms. Earlier actions include executive orders to streamline the Federal Acquisition Regulation (“FAR”), Buy America and Made in America initiatives, and domestic manufacturing and supply of products such as pharmaceuticals and critical strategic minerals.
Key Provisions of the Memorandum
The memorandum directs the Office of Management and Budget (“OMB”) and the U.S. Trade Representative (“USTR”), in coordination with the FAR Council, to identify Canadian-origin items that may be removed or designated as unavailable for purchase by federal civilian agencies. Importantly, the directive does not impose an immediate government-wide ban. Instead, it establishes a process for evaluating and implementing potential restrictions consistent with applicable law.
Agency Responsibilities
Under the memorandum, the OMB director must identify Canadian-origin items eligible for removal, notify agencies of domestic alternatives, and periodically update the president on implementation. The USTR is tasked with monitoring Canada’s treatment of U.S.-origin items in federal and provincial procurement markets and reporting developments. Agency heads are authorized to implement the memorandum within their authority. The directive also permits the USTR to recommend restoring access to Canadian-origin products should Canada change its current policies.
Key Actions for Federal Contractors
Thus, the devil is in the details in terms of products that may be removed or designated as unavailable for civilian agency purchase. Federal contractors and suppliers offering Canadian-origin products should not sit idle. Federal contractors should consider the following actions:
- Audit supply chains to identify Canadian-origin products and identify alternative products that are either domestic or sourced from a Trade Agreements Act designated country (other than Canada);
- Monitor OMB’s identification of Canadian-origin items eligible for removal or designated as unavailable for civilian agency purchase;
- Prepare assessments to counter OMB designations to demonstrate how alternative sourcing could affect such factors as pricing, lead times, patient safety, and contract performance;
- Monitor civilian agency procurements for changes to country-of-origin requirements, solicitation terms, and domestic preference provisions; and
- Monitor USTR’s ongoing assessment, as reversal of restrictions remains contingent on Canadian policy changes.