Controlled Goods Program (CGP)

If you're bidding on defence or security contracts with the federal government, you need to know about the Controlled Goods Program. This regulatory framework, administered by Global Affairs Canada, requires mandatory registration for any business that examines, possesses, or transfers military and certain strategic goods listed under the Defence Production Act. Without registration, you can't legally touch these materials—which means you can't fulfill the contract.

How It Works

The program covers goods on the Controlled Goods List, which includes military equipment, technology, and components that fall under specific categories in the Defence Production Act schedule. Here's the thing: the registration requirement isn't just for prime contractors. Any subcontractor down the chain who will handle controlled goods must also register individually. This catches a lot of companies off guard.

When you're responding to solicitations involving controlled goods, you'll typically see SACC Manual clause A9130T (dated 2014-11-27) incorporated into the contract terms. This clause spells out your obligations under the program. The Supply Manual Version 05-02 from 2005 addresses controlled goods procedures in Chapter 6 on developing procurement strategies, reflecting how integral these requirements are to federal defence procurement.

Registration isn't a quick checkbox exercise. You need to demonstrate adequate security measures for handling controlled goods, and your employees who will access these materials require security screening. The process can take several months, so factor this into your bid timelines if you're new to defence contracting. Public Services and Procurement Canada works with Global Affairs Canada to verify compliance throughout the contract lifecycle.

Key Considerations

• Registration timelines can derail bids. If your proposal depends on subcontractors who aren't already registered, you're looking at potential delays that might make you non-compliant with mandatory criteria. Plan accordingly.

• The requirement follows the goods, not the contract value. Even a small subcontract can trigger registration requirements if it involves examining or possessing controlled goods. Don't assume low dollar values mean you're exempt.

• Subcontractor obligations are non-delegable. As the prime contractor, you're responsible for ensuring every entity in your supply chain that touches controlled goods is properly registered. Due diligence here is essential before you submit your bid.

• Transfer includes electronic transmission. Sending technical data or specifications electronically counts as "transfer" under the program. This affects how you structure your team's information sharing and data management protocols.

Related Terms

Mandatory Criteria vs. Point-Rated Criteria, Security Requirements, SACC Manual

Sources

• Government of Canada Supply Manual, Version 05-02 (2005)

• Controlled goods: Examining, possessing or transferring - Canada.ca

• Export and brokering controls handbook - Global Affairs Canada

Bottom line: if you're pursuing defence work, get your registration sorted early. Waiting until you win a contract puts you at risk of non-compliance before you even start.