Controlled Goods Program (CGP) Registration

Controlled Goods Program (CGP) registration is the registration required in Canada for an individual or organization that examines, possesses, or transfers controlled goods or controlled technology in Canada. An exemption or exclusion can remove the requirement, but without one, registration is mandatory. The rules are set out in the program's registration page.

Public Services and Procurement Canada (PSPC) administers the Controlled Goods Program under the Defence Production Act and the Controlled Goods Regulations. The program regulates access to goods and technical data with military or national-security significance. For suppliers, registration is the entry point to handling that material, and it often comes up in defence-related procurement.

What CGP registration covers

The CGP regulates three activities involving controlled goods in Canada: examination, possession, and transfer. Any person who does one of these things must be registered unless an exemption or exclusion applies. The registration guideline describes registration as mandatory for anyone in this position.

The program covers controlled technology as well as physical goods. Technical data connected to a controlled good falls within the program, so a company that only receives drawings or specifications may still need to be registered.

Controlled goods and the Defence Production Act schedule

Controlled goods are the goods, components, and technical data listed in the Schedule to the Defence Production Act, commonly called the Controlled Goods List. The guide to the Schedule explains how the list is organized and confirms that the CGP operates under PSPC's authority.

The CGP is Canada's domestic industrial-security and access-control program. It was established in 2001, as the 2018-2019 evaluation report notes, and it also addresses access in Canada to certain U.S. articles controlled under the International Traffic in Arms Regulations (ITAR).

Subcontractors and bid-solicitation documents

Registration affects more than the prime contractor. A subcontractor must register if it intends to examine, possess, or transfer controlled goods, including associated controlled technical data, in Canada. PSPC explains the conditions on its page on when subcontractors must register.

Registration can also be needed before a bid is submitted. A supplier may need to be registered or otherwise authorized to receive bid-solicitation documents that contain controlled goods or controlled technology. A bidder without that status can be unable to see the full solicitation package.

Security plans and ongoing obligations

Registration is not the full obligation. Registrants must comply with the Defence Production Act and the Controlled Goods Regulations, including safeguarding requirements. As a condition of registration, a company must establish and implement a security plan for each Canadian place of business where controlled goods are kept. PSPC's security plan guideline sets out what the plan must address.

Related program terms include the Designated Official, the security assessment, and the exempt or excluded person. PSPC publishes forms, templates, and guidelines for each step.

What CGP registration means for suppliers bidding on Canadian public contracts

CanadaBuys identifies CGP registration as the first step for suppliers that need to examine, possess, or transfer controlled goods in Canada. See its guidance on preparing to sell to government.

• Check each solicitation for security requirements and for any mention of controlled goods or controlled technology.
• Confirm your registration status, or whether an exemption or exclusion applies, before you request restricted bid documents.
• Check whether proposed subcontractors will access controlled goods or technical data in Canada, since they must register too.
• Prepare a security plan for every Canadian site where controlled goods will be kept.

Whether registration is required depends on whether the procurement involves controlled goods or controlled technology and on the solicitation's specific security requirements. Starting the process early keeps registration from delaying a bid.