Canadian Content Policy (CCP)

The Canadian Content Policy (CCP) is a Cabinet-mandated Government of Canada policy. It encourages industrial development in Canada by limiting competition for certain government procurement opportunities, in specified circumstances, to suppliers of Canadian goods and services. The policy is described on the CanadaBuys Canadian Content Policy page.

The policy originated in procurements carried out by the former Supply and Services Canada, which is now part of Public Services and Procurement Canada (PSPC). It normally applies to goods and services contracting conducted by the PSPC Acquisitions Program, and the Department of National Defence (DND) must apply it to all applicable transactions or orders when acquiring defence supplies, as set out on the policy application page.

Where the Canadian Content Policy applies and where it does not

The policy normally applies to competitive procurements with an estimated value of $25,000 or more, subject to stated exclusions, according to the application page. It appears in invitations to tender, requests for proposals and requests for standing offers (RFSOs) when the requirement is covered by the policy.

The policy does not normally apply when another federal department conducts its own contracting, or to construction procurement formerly carried out by the former Public Works Canada. Other exclusions include:

• procurements subject to international trade agreements
• certain development-assistance procurements
• procurements conducted by PSPC acquisition offices outside Canada
• Cabinet-mandated sourcing, such as industrial and regional benefits, shipbuilding, ship repair, refit and mid-life modernization

How Canadian goods and Canadian services are defined

The policy depends on the federal definitions of Canadian goods and Canadian services. Standard clause A3050T in the Standard Acquisition Clauses and Conditions Manual sets them out. A Canadian good may be wholly manufactured or originating in Canada. It may also contain imported components if it has undergone the required change in Canada under the applicable CUSMA rules of origin, with "Canada" substituted for the territory of the CUSMA parties.

A Canadian service is generally a service provided by an individual based in Canada. For a single service provided by multiple individuals, the clause states that at least 80% of the total bid price must be provided by individuals based in Canada, as described in the clauses manual.

Solely limited and conditionally limited solicitations

The key considerations guidance for preparing solicitations explains how a covered solicitation is structured. A solicitation may be solely limited to Canadian suppliers when the buyer believes at least two eligible suppliers can meet the requirement. It may be conditionally limited when that number is uncertain. Otherwise it is open to all suppliers.

The same guidance sets thresholds for requirements with several items:

• For an aggregate requirement involving multiple goods, at least 80% of the total offer price must consist of Canadian goods.
• For a requirement involving more than one service, at least 80% of the total offer price must be provided by individuals based in Canada.
• For mixed goods-and-services requirements, the applicable 80% threshold described in the solicitation guidance applies.

How the Canadian Content Policy differs from the Buy Canadian policy

The Canadian Content Policy is a separate instrument from the more recent Policy on Prioritizing Canadian Suppliers and Canadian Content in Strategic Federal Procurements, commonly presented as the Buy Canadian policy. The newer policy uses bid-price discounts and additional evaluation points for strategic procurements. Details are available in the Treasury Board Secretariat policy notice and on the CanadaBuys Buy Canadian policy page. Read each solicitation to see which rules it invokes.

What the Canadian Content Policy means for a supplier

Check the solicitation first to see whether it is solely limited, conditionally limited or open to all suppliers on the basis of Canadian content. Where a certification is required, complete and submit it with the bid, and certify that the goods or services meet the applicable definition. CanadaBuys directs buyers to include Canadian-content certifications when the policy applies, as noted in its guidance on certifications.

Do not leave the certification out. Under standard clause A3050T, failure to provide a required Canadian-goods certification with the bid results in the goods being treated as non-Canadian. That can make the bid ineligible where the competition is limited to Canadian goods or services. For multi-item bids, check the 80% price thresholds before submitting.