Aggregate Certification

When you're procuring a complex system with multiple components—some Canadian-made, others not—calculating Canadian content compliance for each individual item becomes a logistical nightmare. That's where aggregate certification comes in. It lets you assess the overall Canadian content across an entire procurement package rather than certifying each piece separately.

How It Works

Here's the thing: aggregate certification isn't actually a term you'll find explicitly defined in federal procurement documentation. The Supply Manual, which describes PSPC's supply activities, addresses certification processes and Rules of Origin Determination in Annex 5.5, but it doesn't use this specific terminology. What exists instead is a flexible approach to certification that allows for collective assessment when you're dealing with multi-component procurements.

Say you're buying an IT system integration project or a complex defense platform. Rather than having your supplier certify that the servers are 60% Canadian, the software is 40% Canadian, and the installation services are 100% Canadian—each requiring separate documentation—you can look at the weighted average across the entire contract value. If your procurement requires 25% Canadian content under Canadian Content Policy, the supplier demonstrates compliance by showing that the total project meets or exceeds that threshold when all components are considered together. Much simpler on paper.

The Treasury Board's Contracting Policy establishes the broader management framework for these certification practices, but the actual application depends on which trade agreements apply to your procurement and whether Canadian content requirements are even permissible under those agreements. For procurements below certain thresholds or outside trade agreement coverage, you have more flexibility in how you structure certification requirements.

Key Considerations

• Not every procurement allows this approach. You need to confirm with your procurement authority whether collective assessment is appropriate for your specific situation, especially given the lack of explicit policy guidance.

• The catch is that documentation becomes more complex, not less. Your supplier needs to maintain detailed records showing how each component contributes to the overall Canadian content calculation, even if they're submitting a single aggregate certification.

• Trade agreement implications matter significantly. What's permissible under trade agreement thresholds will determine whether you can even impose Canadian content requirements, let alone how you certify them.

• The calculation methodology needs to be clear upfront. Define in your solicitation whether you're weighting by dollar value, by component, or using another method to determine overall compliance.

Related Terms

Canadian Content Policy, Rules of Origin, Trade Agreement Thresholds

Sources

• Supply Manual - Public Works and Government Services Canada

• Contracting Policy - Treasury Board of Canada Secretariat

• Canada Buys - Supply Manual and Procurement Guidelines

Before requesting aggregate certification on your next complex procurement, consult with your departmental procurement team and review Annex 5.5 of the Supply Manual for origin determination rules. The flexibility exists, but the documentation requirements remain stringent.