Controlled Goods Program (CGP)

The Controlled Goods Program (CGP) is the Government of Canada's domestic industrial-security program. It regulates the examination, possession and transfer of controlled goods in Canada. Public Services and Procurement Canada (PSPC) administers it under the Defence Production Act and the Controlled Goods Regulations. See the PSPC guide to the Schedule to the Defence Production Act.

Controlled goods are primarily defence articles, components and technical data with military or national-security significance. The program works as a registration system: persons and organizations that handle these goods must register with the CGP unless they are excluded or exempt. The CGP is a Canadian program run by PSPC, and it is separate from any NATO standard.

What counts as a controlled good

The Defence Production Act identifies the goods the program regulates, and the Controlled Goods Regulations set the registration and compliance requirements. PSPC's overview of controlled goods describes them as goods, components and technical data of military or national-security significance.

Controlled goods can include defence articles and their associated technology, such as blueprints and technical specifications. Some of them correspond to articles on the United States Munitions List (USML), which is controlled under the U.S. International Traffic in Arms Regulations (ITAR). The program therefore covers physical items and the information needed to build or use them.

Who must register and why the program exists

The CGP applies to persons and organizations in Canada that examine, possess or transfer controlled goods. Registration is required unless the person or organization is excluded or exempt. CanadaBuys lists CGP registration as the first step toward being able to examine, possess or transfer controlled goods in Canada, in its guidance on preparing to sell to government.

The program was initiated in April 2001 to strengthen and coordinate defence-trade controls with the United States. PSPC records this in its key events timeline for controlled goods.

How the CGP appears in solicitations

Canadian defence solicitations, including those for the Department of National Defence, can carry CGP requirements when the solicitation or resulting contract involves controlled-goods information, technology or goods. Where a solicitation includes such material, an offeror must generally be registered, exempt or excluded under the CGP before receiving it. One example is this military transportable satellite terminals RFP.

Offerors that want controlled-goods technical-data packages or specifications must request them in writing from the contracting authority. The request must include their CGP registration number or written proof of exemption or exclusion. The same evidence may be required for other persons to whom the offeror will give access.

If a resulting contract requires the production of or access to controlled goods, the solicitation may include SACC Manual clause A9130T, Controlled Goods Program. It appears, for instance, in this IDEaS call for proposals.

Award timelines and access restrictions

A contractor and any subcontractor that examines, possesses or transfers controlled goods must be registered, exempt or excluded under the CGP. In the cited solicitation clauses, a successful offeror or subcontractor that is not already registered, exempt or excluded at contract award must submit the required registration or exemption application within 7 business days of receiving notice of award. This transmission RFP contains that language.

The contract language also requires the contractor to refrain from examining, possessing or transferring controlled goods until it has provided satisfactory proof of CGP registration, exemption or exclusion.

What the CGP means for a supplier bidding on Canadian contracts

Check each defence solicitation for CGP language and for clause A9130T before you bid. If your firm or a subcontractor will handle controlled goods or technical data, confirm your registration, exemption or exclusion status early. You may need your CGP registration number just to receive the technical documents. A firm that is not yet registered should plan to file its application within 7 business days of award and should not touch controlled goods until proof is accepted. The PSPC controlled goods page is the starting point for registration.