Canadian Export Controls

Canadian export control laws regulate the transfer of certain goods, technologies and data to a foreign country, regardless of means of delivery. These laws are designed to protect national security, fulfill international obligations and prevent the proliferation of sensitive technologies. At universities, these controls apply to research activities that involve international collaboration, shipment of materials or sharing of technical data.

Export controls are governed primarily by the Export and Import Permits Act (EIPA) and administered by Global Affairs Canada. The key regulatory instruments include:

• Export Control List (ECL): Items requiring a permit for export.
• Area Control List (ACL): Countries to which all exports require a permit.

Researchers working with sensitive goods and technology may also need to be aware of other distinct but parallel requirements:

• Controlled Goods Program (CGP): Domestic regulation of sensitive goods and technologies with military or national security implications.
• Nuclear Non-proliferation Import and Export Control Regulations (NNIECR): Regulates the export of nuclear and nuclear-related items.

Application for University Research

Research activities often involve the transfer of goods and technologies to advance scientific discovery and innovation. Some examples may include:

• International collaboration and data sharing:
  • Emailing technical schematics to international colleagues.
  • Sharing source code or simulation models.
  • Presenting sensitive research at international conferences.
  • Collaborating with foreign nationals in labs or classrooms.
• Travel with research equipment or samples (e.g., computer hard drives, memory sticks, books, records, etc.).
• Use of U.S.-origin technology (e.g., U.S.-origin software).
• Industry-sponsored projects with sensitive applications.

Even intangible transfers, such as emailing technical data or uploading software to the cloud, can be subject to export controls.

Violations can result in:

• Fines up to $25,000 or imprisonment under Canadian law.
• Severe penalties under U.S. law if U.S.-origin items are involved.
• Loss of research funding or access to international partnerships.

Export controls are not meant to hinder academic freedom but to ensure responsible research practices in a global context. By understanding and complying with these regulations, researchers help protect Canada’s national interests and maintain the integrity of international collaborations.

What Items are Controlled?

Canada’s Export Control List (ECL) includes military goods, dual-use technologies, nuclear materials, missile systems and certain chemical and biological agents. It also covers U.S.-origin items and strategic goods like encryption tools and aerospace components. These controls help Canada meet international obligations and protect national security. Researchers and exporters must check whether their items fall under these categories before transferring them internationally. Refer to A Guide to Canada's Export Control List for a full listing.

Controlled items include:

• Military and dual-use technologies.
• Nuclear materials and equipment.
• Advanced electronics and software.
• Technical data and blueprints.
• Certain chemicals and biological agents.

Examples of Activities that May Trigger Export Controls:

• Designing components for aerospace or defense applications.
• Using simulation software with encryption capabilities.
• Collaborating with international partners on robotics or AI.
• Sending prototypes or samples abroad for testing.
• Publishing sensitive technical data online.

What is the Controlled Goods Program?

Some of the most sensitive goods and technology are controlled even when remaining in Canada. The Controlled Goods Program is a stringent security system mandated by the Defense Production Act (DPA) of Canada that regulates and controls the domestic examination, possession or transfer of controlled goods. Anyone who deals with controlled goods listed in the DPA in Canada is required to register with the Controlled Goods Program, including researchers contracting with industry and other non-academic partners.

Some examples of controlled goods that are covered by the program include firearms and ammunition, many different kinds of munitions, and aerospace, satellite and other goods/ technologies that guide weapons, satellite and navigation systems.  View the full Controlled Goods List.

If goods or technology regulated under the Controlled Goods Program require examination, possession or transfer to a foreign entity or national, an export permit under Canada’s Export Control Regulations is also required.

What are the Nuclear Non-proliferation Import and Export Control Regulations?

Certain exports of nuclear and nuclear-related items also require licences from the Canadian Nuclear Safety Commission. There are also nuclear and nuclear-related items not listed in the Export Control List that are controlled under the Nuclear Safety and Control Act and require licences from the Canadian Nuclear Safety Commission prior to exportation.

Exports of Export Control List Group 3 and 4 items that are also subject to control under the Nuclear Safety and Control Act can only occur when export authorizations are obtained from both Global Affairs Canada and the Canadian Nuclear Safety Commission.

Responsibilities of Researchers

Researchers must:

• Identify whether their work involves controlled goods or technology.
• Consult with the Office of Research Services before transferring items.
• Apply for export permits when required.
• Avoid relying on “fundamental research” exemptions, especially in industry collaborations.

If your project involves goods and technology subject to the Controlled Goods Program, you may also need:

• Security assessments for personnel.
• Training in handling and transporting controlled items.
• An export control permit.

How to Apply for an Export Control Permit

Step 1: Determine if your goods and/or technology appear on the ECL by consulting A Guide to Canada's Export Control List.

Step 2: Complete the export permit application web form.

Step 3: The Office of Research Services will submit the online application using Ontario Tech’s NEXCOL account.

Step 4: Await approval and issuance of the permit. Applicants should allow up to six weeks for processing.

Step 5: The transfer of goods and technology can commence.

Training and Education

Two workshops are available on the Ontario Tech Catalog Canvas platform. To register, email your Banner ID to safeguardingresearch@ontariotechu.ca. It may take up to one week to receive a welcome email with a link to access the courses.