301 FW 6
Promotional Items

Supersedes 301 FW 6, 07/06/11

Date:  April 6, 2017

Series: Contracting

Part 301: Acquisition Policies and Procedures

Originating Office: Division of Contracting and Facilities Management



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6.1 What is the purpose of this chapter?

6.2 What is the scope of this chapter?

6.3 What are the authorities for this chapter?

6.4 What are promotional items?

Process for Approval

6.5 Who reviews promotional item acquisitions to approve the use of appropriated funds?


Appropriated Funds for Promotional Items and Services

6.6 When may employees use appropriated funds to buy promotional items?

6.7 May employees use appropriated funds for promotional services?





6.1 What is the purpose of this chapter? This chapter:


A. Establishes U.S. Fish and Wildlife Service (Service) policy on purchasing and using promotional items, including publicity expert services, informational/educational materials (I/E), and gifts for foreign officials; and


B. Identifies who reviews and approves the purchase of promotional items.


6.2 What is the scope of this chapter? This chapter covers the purchase of promotional items. It does not apply to items we use as awards to recognize achievements of employees, volunteers, and other citizens. (See 224 FW 5, Nonmonetary Recognition and Informal Honors, and 150 FW 3, Volunteer Program Operations, for further information on these topics.)


6.3 What are the authorities for this chapter? See 301 FW 1 for a list of the authorities for all of the chapters in Part 301. The following authorities are specific to promotional items:


A. Money and Finance, The Budget Process, Appropriations (31 U.S.C. 1301(a)).


B. Authority for Employment, Employment of Publicity Experts, Restrictions (5 U.S.C. 3107).


C. Executive Order 13589, Promoting Efficient Spending.


D. Memorandum from the Deputy Assistant Secretary – Budget, Finance, Performance, and Acquisition; March 29, 2012, “Restriction on the Purchase of Promotional Items.


E. Department of the Interior Acquisition, Assistance, and Asset Policy 0038 (DOI-AAAP-0038), “Restriction on the Purchase of Promotional Items.”


6.4 What are promotional items?


A. Promotional items typically have a logo, design, slogan, or name on them to promote a place, program, event, or idea that is directly mission-related. They are usually inexpensive.


B. They include items for:


(1) Distribution at meetings and conferences,


(2) Recruitment activities such as job fairs,


(3) Informational or educational purposes to promote an initiative or appropriated program, and


(4) Gifts to foreign officials in the interest of diplomacy and protocol.


C. Promotional item examples may include, but are not limited to:


(1) Conference materials, such as agendas, lapel pins, name tags, notepads, pens, and portfolios tent cards;


(2) Informational or educational items, such as pamphlets, books and reports, posters, coloring books and games, teacher’s guides and video programs (information about Service interpretation and education programs can be found at 605 FW 6 and 605 FW 7); and


(3) Other items, such as plaques, clothing, hats, tote bags, pins, recognition coins, cups, water bottles, USB drives, mouse pads, posters, stickers, commemorative items, key rings, ice scrapers, pencils, decals, lanyards, magnets, bookmarks, bumper stickers, calendars, balloons, and candy.


D. Promotional items do not include the routine publication of notices and advertisements for procurement and recruiting purposes.



6.5 Who reviews promotional item acquisitions to approve the use of appropriated funds?


A. Program managers and supervisors must ensure that all expenditures for promotional items, including those bought with a Government credit card, are allowable and that their employees have completed the required justifications and attached them to the acquisition request. (For information on what needs to be in the justification, see the Justification for the Purchase of Promotional Items (FWS Form 3-2486).


B. Requests under the micro-purchase limit must be sent to the Regional Chief of the Contracting Office (CCO) (the Acquisitions Branch Chief is the CCO for Headquarters). If approved, the CCO sends the request to the Bureau Procurement Chief (BPC) (i.e., Chief, Contracting and General Services, Headquarters) for approval. Justifications must be approved at a level no lower than the BPC (DOI-AAAP-0038).


C. Requests over the micro-purchase limit are sent to a Contracting Officer first, and then the CCO before BPC approval. Contracting Officers must review these requests and ensure that there is adequate signed documentation to support the specific acquisition requirements for promotional Items (see DOI-AAAP-0038), gifts to foreign officials, and publicity expertise (the appropriation must be specifically for that purpose).


D. Contracting personnel must note violations of this policy when performing acquisition management reviews.



6.6 When may employees use appropriated funds to buy promotional items?


A. Employees must not spend appropriated funds for promotional items unless the acquisition:


(1) Is specifically authorized by statute, or


(2) Is integral to accomplishing a program or project.


            (a) To use this reason to purchase items, you must write a justification and have it approved at a level no lower than the BPC (see section 6.5B).


            (b) You must attach the signed justification to the acquisition request and send it to the appropriate CCO or Contracting Officer (see sections 6.5B and C).


            (c) To request a purchase of promotional items using appropriated funds, you should be able to answer “yes” to the question, “Will this program suffer or fail if these promotional items are not purchased?” See DOI-AAAP-0038 for additional information.


B. See Principles of Federal Appropriations Law, volume 1, chapter 4.C.8 for more information. 


6.7 May employees use appropriated funds for promotional services?


A. Promotional services are services that we hire individuals or companies (including the mass media) to provide that publicize specific places, programs, people, events, or ideas. Promotional services include paid advertising and the use of advertising agencies. (For paid advertising, see 115 FW 1, Official Public Communication – General Policies and Procedures, and the Federal Acquisition Regulation (FAR) Subpart 5.5, Paid Advertisements.)


B. The Comptroller General does not generally treat procurements of promotional services as inherently questionable. As with any expenditure of appropriated funds, these procurements must be either explicitly authorized by law or necessary to accomplish a program or project (e.g., promoting the purchase of stamps for the Federal Duck Stamp program).


For more information about this policy, contact the Division of Contracting and General Services. For more information about this Web site, contact Krista Bibb in the Division of Policy, Performance, and Management Programs.



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