Controlled goods

Research at the University of Waterloo may involve materials and data that are subject to controls by federal law, or equivalent international rules and regulations. It is the researcher’s responsibility to be aware of any restrictions on the use or transfer of materials and data that may be created or received during their research.  

Some materials and data are prohibited from being imported or exported without permits. Additionally, individuals who access these materials may require a security assessment. The Office of Research must be notified well in advance of any research involving materials that may be subject to any controls.

We understand that this is a very complicated subject. The Office of Research will support researchers and guide them through applicable processes to ensure compliance with all Canadian and foreign controlled goods regulations.

Controlled Goods at the University of Waterloo

Controlled Goods Program

The Controlled Goods Program (CGP) is a federal government registration and compliance program that regulates and controls the examination, possession, and transfer in Canada of controlled goods and technology, including U.S. International Traffic in Arms Regulations (ITAR) items. The CGP was established to prevent and detect the unlawful examination, possession, or transfer of controlled goods in Canada. It is intended to safeguard controlled goods within Canada and prevent them from being accessed by unauthorized persons. 

The overall mission of the program is to prevent the proliferations of weapons of mass destruction and conventional weaponry. 

Definitions: 

Examine: Means to consider in detail or subject to an analysis in order to discover essential features or meaning. 

Possess: Either actual possession, where a person has direct physical control over a controlled good at any given time, or constructive possession, where the person has the power and the intention at a given time to exercise control over a controlled good, either directly or through another person or persons. 

Transfer: means in respect of a controlled good and/or controlled technology to dispose of it or disclose its content in any manner. 

Under the authorities of the Defence Production Act (DPA) and the Controlled Goods Regulations, the CGP's mandate is to strengthen Canada's defence trade controls through the mandatory registration and regulation of businesses and individuals who examine, possess and/or transfer controlled goods. The items that are controlled goods are listed in Section 35 of the DPA. The list of controlled goods is partially based on the Export Control List (ECL). 

Violation of the DPA may result in fines to the individual or University from $25,000 to $2,000,000 per day of non-compliance, and/or 10 years imprisonment. 

What are Controlled Goods?

According to the Controlled Goods Program, controlled goods are primarily goods, including components and technical data that have military or national security significance, which are controlled domestically by the Government of Canada and defined in the DPA. 

Controlled goods fall into one of the following groups, as listed in the Export Control List: 

Group 2 

Munitions List (Wassenaar Arrangement): Automatic weapons, firearms, ammunition, components, projectors, bombs, fighter jets, tanks, missiles, chemicals, explosives, and related equipment and components, etc. 

Group 5 (Item 5504) 

Strategic Goods: Global navigation satellite systems, ground control stations, and nuclear weapon design and testing equipment 

Group 6 

Missile Technology Control Regime: Missile technology – rocket systems, unmanned air vehicle systems, propulsion components and equipment 

Technology 

Not only are the physical goods controlled, but also the technology that supports the goods. In other words, this refers to the technology required to develop, produce, or use a controlled good. Examples may include technical data, such as blueprints, formulas, engineering designs, or models, and technical assistance, such as instructions, training, and working knowledge related to controlled goods. 

The following constitutes examples:  

  • goods, including components and technology (for example, blueprints and technical specifications in paper or electronic format), with strategic significance or national security implications, regardless of where they are manufactured; 

  • defense articles originating from the United States that are controlled by the United States Munitions List—part 121 of the United States International Traffic in Arms Regulations; 

  • goods, regardless of where they are manufactured, that are manufactured from technical data originating from the United States and are controlled by the International Traffic in Arms Regulations. 

The Guide to the Schedule to the Defence Production Act provides a simplified listing of the items that are identified as controlled goods in the DPA. This guide helps identify whether an item is included on the Controlled Goods List.  

Controlled Goods and Researchers - Roles and Responsibilities

Research at Waterloo can involve access to or the development of controlled goods. Researchers whose project involved controlled goods or technology must obtain security clearance and training.  Everyone on a research project who could examine, possess, or transfer controlled goods must be registered. Only Canadian citizens or permanent residents are eligible for registration. However, foreign students or visiting scholars may be eligible for an exemption.  

Applications for registration or exemption require a security assessment.   

Researchers who may receive or produce controlled goods must notify the Designated Official well in advance of the research project. For more information, see Controlled Goods Program. 

Researchers, including students, must not engage in research involving controlled goods until all relevant permissions and clearances have been obtained. 

Security Assessment Process

All individuals (principal investigators, co-investigators, post-doctoral fellows, students, university staff) requiring access to controlled goods must register with the Controlled Good Program and must undergo a security assessment conducted by the Designated Official. 

Canadian citizens or permanent residents who normally reside in Canada will have their security assessments completed by the Designated Official. Those who are not Canadian citizens or permanent residents ordinarily resident in Canada will have their security assessments undertaken by the Controlled Goods Directorate after receiving an application submitted on their behalf by the Designated Official.   

Registration conducted by the Designated Official take approximately three weeks. 

Registration conducted by the CGP can take up to 45 days from the time the application is submitted. 

The Security Assessment process includes applicants submitting to the Designated Official, Jennifer Ranford, the following: 

  • A completed Security Assessment Application  

  • Two pieces of government-issued identification (at minimum one must be a valid photo ID) 

  • Proof of residence (government issued ID, such as driver’s license, or gas/hydro bill) 

  • Proof of citizenship (birth certificate, passport, Nexus card, permanent resident card) 

  • Study or work permit issued by the Government of Canada (if not a Canadian citizen or permanent resident) 

  • Fingerprint Criminal Records Check report 

  • International criminal records checks (e.g., Certificate of Good Conduct or Police National Certificate). This is required if applicant a) is not a Canadian citizen or permanent resident or b) has lived outside of Canada for more than 6 consecutive months over the past 5 years. 

  • Curriculum Vitae  

  • Evidence of educational history (e.g., diploma or degree) if you have attended an educational institution during the last 5 years. 

For a Canadian citizen or Permanent Resident, registration under the Controlled Goods Program is valid for five years.