Response to Proposed ‘Buy Ontario’ Policies
Purpose Establish 'Buy Ontario' policies under the Buy Ontario Act (Public Sector Procurement), 2025 for light duty fleet vehicles and construction procurements to promote, protect and build Ontario's economy and businesses and safeguard Ontario's domestic supply chains.
Proposal Number 26-MPBSD001 (Ontario Ministry of Public and Business Service Delivery and Procurement)
Submission Date March 2, 2026
Overview
The Ontario Chamber of Commerce (OCC) welcomes the opportunity to respond to the Ministry of Public and Business Service Delivery and Procurement’s consultation on proposed ‘Buy Ontario’ policies under the Buy Ontario Act, 2025. As Canada’s largest and most influential provincial chamber, the OCC represents 60,000 businesses of all sizes, sectors, and regions – many of whom participate in public-sector procurement.
As outlined in our 2026 Ontario Economic Report, while most businesses are not optimistic about the province’s economic outlook, one strong positive indicator is strong business support for measures that stimulate domestic economic growth, including “buy/travel local” campaigns (44 per cent), preference for domestic sources in procurement (32 per cent), and domestic manufacturing capacity and supply chains (26 per cent).
As such, the OCC supports policies that strengthen Ontario’s economic resilience, domestic capacity, and supply chains while preserving interprovincial trade, labour mobility, patient care, infrastructure quality, and access to essential goods, services, and expertise.
Effective implementation will require clear direction for municipalities, local boards 1, and other Broader Public Sector entities to ensure compliance obligations do not compromise local procurement autonomy where appropriate, trade agreement commitments, value-for-money outcomes, or the health, safety, and jobs of Ontarians.
Proposed ‘Buy Ontario’ policies hold particular interest for Canada’s medical device industry, nearly half of which is based in Ontario, employing over 31,000 people and generating $22.3 billion in annual revenue
1 As defined by the Municipal Act, 2001, local boards are independent bodies established by municipalities or the province to manage specific public services or local needs such as transit, libraries, or health. Common examples include Local Services Boards, Public library boards, police services boards, planning boards, and boards of health.
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This reflects the province’s position as a national hub for research, innovation, and manufacturing. 2 Ontario’s technical workforce, including infrastructure, engineering, and architecture, contributes $16.5 billion to provincial GDP, supporting cross-sector economic activity. 3
To balance economic development with the public interest, the Buy Ontario Act, 2025 should preserve fair and open competition where domestic supply is limited; protect public safety, technical quality, and value for money in health-critical, engineering-intensive, and infrastructure procurements; and support SMEs through clear definitions and predictable procurement rules.
As such, we have several recommendations to ensure the policies under the act live up to their intent, in four key areas.
1. Safeguard Resilient Supply Chains and SME Competitiveness
Ontario’s manufacturing capacity for medical technologies, devices, and critical infrastructure components is limited and geographically concentrated, leaving many essential products without viable Ontario or Canadian-made equivalents. Procurement policies must preserve competition, avoid single-supplier lock-in, and maintain diversified, multi-supplier arrangements to ensure continuity of care, infrastructure reliability, and that SMEs remain active contributors to Ontario’s value chain, Broader Public Sector entities (BPS), and communities
Recommendations:
• Embed a clear commitment that no ‘Buy Ontario’ policy may restrict access to care or compromise patient and public safety. This includes:
o Providing clear exemptions or alternate procurement pathways for critical public infrastructure, when Ontario‑made options do not meet cost, quality, interoperability, or availability requirements.
• Avoid Ontario content thresholds that create de facto single supplier advantages, which can limit competition, stifle innovation, reduce pricing discipline, and weaken supply security.
• Recognize when global medical technology/device and infrastructure supply chains are essential to the continuity of service.
• Exempt essential medical devices, health technologies, life sciences products, and health capital infrastructure projects (e.g., medical imaging systems, life-support devices, and surgical and laboratory/diagnostic systems), to ensure uninterrupted access to patient care and safety.
• Assess and support Ontario and Canadian vendor capacity to meet increased demand under ‘Buy Ontario’ requirements, particularly in capital and construction procurement, to prevent cost escalation, supply shortages, or project delays.
2 https://www.investontario.ca/digital-healthmedtech#:~:text=Excel%20in%20Ontario's%20Booming%20Digital,Ontario's%20global%20reach%20and%20compet itiveness
3 https://www.oacett.org/getmedia/e1be6528-c23d-4af7-a108-85d15b7e869a/CBoC_OACETT-Report_2025-1126_FINAL.pdf
2. Advance Value-Based Procurement and Long-Term System Performance
Ontario’s ‘medtech’ and infrastructure ecosystems span engineering, construction, architecture, skilled trades, and advanced manufacturing. Procurement frameworks should reflect this multidisciplinary environment through transparent, value-based models that prioritize reliability, performance, interoperability, and total cost of ownership, while recognizing legitimate Ontario value-added activities. Together, this would help attract top suppliers and strengthen overall system performance.
Recommendations:
• Incorporate a procurement framework that prioritizes clinical outcomes, reliability, interoperability, and system readiness. This includes:
o Leveraging new and emerging technologies to streamline the procurement process.
o Maintaining and expanding multi supplier frameworks for critical medical devices and diagnostics to ensure continuity of supply and support system wide resilience.
• Recognize local assembly, customization, integration, and servicing as legitimate Ontario value added activity, regardless of where components originate.
• Embed lifecycle cost and maintenance planning as core evaluation criteria, which would benefit high-value local products in a trade-compliant manner
• Provide clear, standardized implementation guidance for municipalities, local boards, and other public-sector entities to operationalize domestic content requirements. This includes:
o Establishing clear, consistent definitions of “Ontario-made” and “Canada-made” to ensure predictable application across jurisdictions and public-sector entities.
o Outlining standardized approaches to verify vendor supply chains and certify compliance without creating disproportionate administrative burden or procurement delays.
o Providing direction on how Ontario/Canadian content should be evaluated and scored in procurement processes while managing value-for-money obligations, cost escalation risks, and project timelines.
o Clarifying how local boards will be captured under the framework, as many operate under distinct procurement policies.
o Ensuring entities retain appropriate flexibility to set local procurement policies and pursue best value-for-money outcomes within the prescribed provincial framework.
3. Strengthen Technical Expertise and Qualifications in Infrastructure Procurement
Ontario’s infrastructure projects require procurement models and strong technical and engineering oversight that prioritize safety, durability, and long term value. Ensuring qualified expertise in both project selection and compliance processes will reduce risk, mitigate delays, and enhance lifecycle performance.
Recommendations:
• Mandate Qualifications-Based Selection (QBS) for engineering and other professional services tied to public safety and complex infrastructure projects, selecting firms based on competence, experience, and technical expertise, with fees negotiated thereafter. This includes:
o Encouraging competition based principally on quality rather than price suppression.
o Reducing lifecycle costs and project risk.
o Supporting innovation and long-term infrastructure performance.
• Require appropriate technical and engineering expertise in compliance reviews and oversight mechanisms for large or technically complex procurements. Ensure risk assessments are integrated into compliance criteria to effectively evaluate safety, risk, innovation readiness, and system reliability.
4. Maintain Interprovincial Trade Alignment and Labour Mobility
Ontario firms operate within highly integrated national supply chains where consistency, transparency, and coordination are essential to maintaining efficiency and competitiveness. ‘Buy Ontario’ implementation should reinforce, not fragment, interprovincial trade and labour mobility frameworks. Alignment with federal and provincial partners would help strengthen competition across jurisdictions, reduce administrative burden, protect value for Ontarians, and preserve market access for Ontario businesses.
Recommendations:
• Collaborate with the federal government and other provinces/territories to:
o Maintain a coordinated “One Canada” approach for products, services, and expertise; and,
o Harmonize any Ontario preference framework with federal procurement standards and Buy Canadian rules.
• Avoid duplication, uncertainty, administrative burden, and fragmented rules that complicate tenders.
• Design ‘Buy Ontario’ directives that promote an open and competitive interprovincial market to protect Ontario exporters, enhance access to other provincial markets, support workforce flexibility and mobility, and strengthen national economic integration.
• Ensure implementation guidance clearly addresses municipalities’ and local boards’ obligations under domestic and international trade agreements to prevent inadvertent non-compliance.
About the Ontario Chamber of Commerce
The Ontario Chamber of Commerce (OCC) is the indispensable partner of business and Canada’s largest, most influential provincial chamber. It is an independent, non-profit advocacy and member services organization representing a diverse network of 60,000 members. The OCC convenes, mobilizes and empowers businesses and local chambers in pursuit of its purpose: to bring inclusive and sustainable prosperity to Ontario’s businesses, workers, and communities.