Your company just landed its first defence contract. The equipment is ready to ship, the timeline is tight, and then someone asks: “Is your crating provider registered under the Controlled Goods Program?” If you don’t know the answer—or worse, if the answer is no—you have a problem that can’t be solved with overnight shipping.
The Controlled Goods Program (CGP) is the federal framework that governs who can legally handle defence-related goods and technology in Canada. It’s administered by Public Services and Procurement Canada’s Controlled Goods Program, and it exists for a straightforward reason: sensitive military technology needs to stay in trusted hands. What many suppliers don’t realize until they’re already committed to a contract is that CGP registration requirements extend far beyond their own organization. Every entity that touches controlled goods—including the company that builds your shipping crates—must be registered.
We’ve been navigating these requirements since we first obtained our CGP registration, and we’ve watched companies stumble into compliance gaps that cost them contracts, timelines, and credibility. This guide explains what CGP registration means for your supply chain, who needs to register, and how to verify that your logistics partners won’t break your compliance chain.
Who This Guide Is For (and Who It’s Not For)
This article is written for defence suppliers, manufacturers, and logistics coordinators who need to understand CGP requirements—either because you’re entering the defence industry for the first time or because you’re auditing your existing supply chain for compliance gaps.
This guide is for you if:
- You manufacture or supply components for defence contracts
- You’re a procurement officer vetting logistics partners for controlled goods handling
- You’re a compliance officer verifying that your supply chain meets CGP requirements
- You’re an operations manager planning logistics for your first defence shipment
This guide is not for you if:
- You ship only commercial goods with no defence applications
- You’re looking for step-by-step registration instructions (we’ll point you to PSPC for that)
- You need detailed information about what items are classified as controlled goods (PSPC maintains the official Controlled Goods List)
What the Controlled Goods Program Is and Why It Exists
The CGP is Canada’s domestic industrial security program for defence articles and related technical data. It creates a framework that allows legitimate defence industry operations while preventing sensitive military technology from reaching unauthorized hands.
Here’s what that means in practical terms: if your business involves examining, possessing, or transferring controlled goods within Canada, you must be registered before you can legally handle those goods. This isn’t optional, and it isn’t something you can sort out after the fact. Failure to register may constitute an offence under federal law, leading to prosecution and sanctions.
The program covers a broad range of defence materials:
- Military equipment components
- Protective gear and vehicle parts
- Aircraft and unmanned systems
- Technical data including blueprints, CAD models, and specifications
That last category catches many companies off guard. Technical data is treated the same as physical goods under CGP. If your engineers need to review drawings for a controlled component, they need to be working for a registered organization.
Who Must Register in the CGP
The registration requirement applies to individuals and organizations who examine, possess, or transfer controlled goods. Those three verbs—examine, possess, transfer—are the key to understanding whether CGP applies to your operations or your partners’ operations.
Examine means reviewing or inspecting controlled goods or their technical data. This includes reading blueprints, analyzing specifications, or visually inspecting equipment.
Possess means having physical control of controlled goods. This includes warehousing, temporary storage, and physical handling during packaging or crating operations. If your crating provider holds your controlled goods while building a custom crate around them, that’s possession.
Transfer means moving controlled goods between facilities, shipping domestically, or disclosing technical content to another party.
Registration requires Canadian citizenship or permanent residency for individuals, security assessments, and demonstration of legitimate business need. Organizations must appoint a designated official who completes mandatory training and oversees compliance.
What “Examine, Possess, Transfer” Means for Your Supply Chain
Let’s translate those regulatory terms into the operations you manage every day.
Your Engineers Can’t Review Technical Drawings Without Registration
If your company isn’t registered and you receive technical specifications for a controlled component, your team legally cannot review those documents. This applies to CAD files, assembly instructions, testing procedures—any technical data related to controlled goods.
Your Warehouse Can’t Store Controlled Goods Without Registration
This is where supply chain gaps often emerge. You might have a CGP-registered manufacturing operation, but if you use a third-party warehouse that isn’t registered, those goods cannot legally sit in that facility. The same applies to:
- Freight forwarders holding goods in transit
- Crating and packaging facilities
- Any temporary storage location
Moving Goods Between Facilities Requires Registration on Both Ends
Transfer includes internal movements between your own facilities and external shipments to customers or partners. If you’re shipping controlled goods domestically, the receiving party must be registered. For exports, you’ll also need permits from Global Affairs Canada export controls.
Consider this scenario: Your manufacturer ships controlled components to an unregistered packaging facility. Both parties may be in violation. The manufacturer transferred controlled goods to an unauthorized recipient. The packaging facility is possessing controlled goods without registration. Your compliance chain is broken.
How CGP Registration Works
We won’t duplicate the detailed registration instructions that PSPC provides—they’re the authoritative source, and registration specifics can change. Here’s what you need to know at a planning level:
- Applications are submitted to PSPC with supporting documentation demonstrating eligibility and business need
- Security assessments are conducted for individuals who will access controlled goods
- Processing currently exceeds 32 business days due to a surge in applications—plan accordingly
- Registration must be renewed periodically and kept current
The critical point: registration must be completed before handling controlled goods. You cannot start operations and register retroactively. If you’re bidding on a defence contract and you’re not yet registered, factor the registration timeline into your project planning.
How Unregistered Handlers Break Your Compliance Chain
This is where we see companies run into trouble. CGP compliance isn’t just about your organization—every entity that touches controlled goods must be registered. An unregistered party anywhere in the chain creates liability for everyone involved.
The Compliance Chain in Practice
Picture your controlled goods moving through a typical supply chain:
- Your manufacturing facility (registered)
- Transport to a crating facility (the truck driver doesn’t need registration if they don’t examine the goods, but the crating company does)
- Custom crating and packaging (must be registered to possess the goods)
- Warehousing while awaiting pickup (must be registered)
- Freight forwarding and final delivery (receiving party must be registered)
If any link in that chain isn’t registered, you have a compliance gap.
Red Flags: Signs Your Supply Chain Has a CGP Gap
- Your logistics partner can’t produce CGP registration documentation when asked
- Your crating provider doesn’t ask about the nature of your goods before accepting the job
- A warehouse offers to store your defence shipment without verifying your authorization
- A freight forwarder treats controlled goods the same as commercial freight
- Partners aren’t listed in PSPC’s registered persons directory and can’t provide direct verification
What Happens When Goods Reach Unregistered Handlers
The consequences cascade:
- Potential federal violations for both the shipper and the receiver
- Contract breaches with your defence customer
- Export permit complications if the goods were destined for international delivery
- Security clearance implications that can affect future defence work
- Reputational damage with prime contractors who need reliable supply chain partners
How to Verify Your Partners’ CGP Status
Due diligence on CGP registration should be part of your standard vendor qualification process for any partner who will handle controlled goods.
Use PSPC’s Registered Persons Directory
PSPC maintains a searchable directory of registered persons, updated daily. This is your first verification step. However, some registrants opt out of public listing, which means absence from the directory doesn’t confirm non-registration—it requires direct verification.
Request Registration Documentation Directly
Ask potential partners for:
- Their CGP registration number
- Confirmation of what controlled goods categories they’re registered for
- The name of their designated official
- Documentation of their most recent registration renewal
A legitimate CGP-registered partner will have this information readily available and will understand why you’re asking.
Verify Facility Security Measures
CGP registration requires physical security measures at facilities where controlled goods are handled. Your partners should be able to describe:
- How controlled goods are segregated from other inventory
- Access control measures limiting who can enter controlled areas
- Documentation procedures for chain of custody
- How they manage subcontractors who might be present in their facility
What to Look for in a CGP-Registered Logistics Partner
Beyond basic registration verification, evaluate potential partners on their operational fit for defence logistics:
Relevant Experience
Has the partner handled controlled goods shipments before? Defence logistics have requirements that commercial shipping doesn’t. Partners with defence experience understand the documentation, security, and chain-of-custody expectations.
Complementary Certifications
CGP registration is essential, but it’s often one part of a broader compliance framework. For international shipments, you’ll also need ISPM-15 certification for wood packaging to clear customs in most countries. Review your partners’ full certifications and compliance framework to ensure they can support your complete logistics requirements.
Subcontractor Management
CGP requires that subcontractors who will examine, possess, or transfer controlled goods must register independently—they can’t operate under their client’s registration. Ask how potential partners manage:
- Trades and maintenance personnel in their facility
- Security staff with access to controlled areas
- Any other subcontractors who might come into contact with controlled goods
Geographic and Operational Fit
For recurring shipments, a partner within practical distance of your facility simplifies logistics. Consider whether they offer services that reduce handling steps—onsite crating, warehousing, or integrated logistics—since fewer handoffs mean fewer opportunities for compliance gaps.
CGP Registration and Canada’s Defence Industry Expansion
Understanding CGP requirements matters more now than it has in years. Canada’s commitment to 2% NATO spending and the broader Canada’s Defence Industrial Strategy are expanding defence procurement significantly. More manufacturers and suppliers are entering defence contracts for the first time.
Many of these companies don’t realize CGP applies to them until they’re already committed to a contract. By that point, the 32+ business day registration timeline creates real problems:
- Bidding inaccuracies if you didn’t factor registration into your timeline and costs
- Delivery delays if you can’t legally handle goods you’ve already contracted to ship
- Supply chain scrambles when you discover your usual logistics partners aren’t registered
The companies handling this well are those who understand CGP implications before they sign contracts. They budget for registration costs and timelines. They qualify CGP-registered logistics partners in advance. They structure compliant supply chains from contract inception rather than retrofitting compliance after the fact.
Your Next Steps
If you’re entering the defence supply chain or auditing your existing operations, here’s a practical sequence:
- Verify your own registration status if you’ll be examining, possessing, or transferring controlled goods. If you’re not registered and need to be, start the process now—the timeline is longer than you might expect.
- Audit your supply chain for unregistered handlers. Map every entity that will touch your controlled goods: warehouses, freight forwarders, crating and packaging providers, receiving facilities. Verify CGP registration for each.
- Qualify CGP-registered logistics partners before you need them. Having verified partners in place when a contract arrives means you can respond with accurate timelines and confident compliance.
- Document your compliance chain. Maintain records of partner registrations, verification dates, and chain-of-custody procedures. If questions arise later, you’ll have evidence of due diligence.
CGP registration isn’t a box to check—it’s a framework that governs how controlled goods move through your supply chain. Understanding that framework, and building relationships with registered partners who understand it too, positions you to pursue defence contracts with confidence rather than compliance anxiety.
Frequently Asked Questions
How does a non-registered crating or logistics partner put our defence contract at risk?
If a crating shop or warehouse that we use is not registered under the Controlled Goods Program, they cannot legally possess or examine our defence-related equipment or technical data. That breaks our compliance chain the moment controlled goods enter their facility. The impact is concrete: we risk federal violations, contract breaches, delivery delays, and reputational damage with prime contractors. We cannot fix this with rush shipping; we must fix it by using only CGP-registered handlers.
Why do our engineers and warehouse team need CGP registration before we even start a project?
Under the Controlled Goods Program, anyone who examines, possesses, or transfers controlled goods or related technical data must be registered before touching them. That includes engineers reviewing CAD files and warehouse staff storing defence components. If we accept drawings or receive parts before registration is approved, we are already non-compliant. The 32+ business day processing time means we have to plan registration early or we will miss milestones and risk losing contracts.
What practical steps can we take to avoid hidden CGP gaps in our supply chain?
We start by mapping every entity that will touch controlled goods—our own facilities, third‑party warehouses, crating providers, freight forwarders, and receiving sites. Then we verify each partner’s CGP status using PSPC’s directory and direct documentation requests. We ask for registration numbers, renewal dates, designated officials, and security procedures. Finally, we document this chain of custody. This systematic approach exposes weak links before a shipment is booked, not after a violation occurs.
How should we vet a CGP-registered logistics or crating partner beyond just their registration number?
We treat registration as the baseline, not the finish line. We ask whether they have handled defence shipments before, how they segregate controlled goods, and how they manage access to secure areas. We check complementary certifications such as ISPM‑15 for wood packaging, since customs clearance depends on them. We also probe how they manage subcontractors in their facilities. The goal is a partner whose day‑to‑day operations match CGP requirements, not one who simply holds a certificate.
How do Canada’s defence spending commitments change the urgency of getting our CGP compliance right?
With Canada committing to higher NATO spending and expanding its Defence Industrial Strategy, more firms are entering defence contracts for the first time. That surge drives CGP application timelines beyond 32 business days and exposes inexperienced suppliers to compliance mistakes. If we ignore CGP until after signing, we face bidding inaccuracies, delivery delays, and last‑minute scrambles to replace unregistered partners. Understanding CGP early lets us price accurately, protect schedules, and build a reliable, compliant supply chain from day one.
