Research conducted at Canadian universities increasingly intersects with global partners, advanced technologies and sensitive materials—making it essential for researchers to understand their responsibilities under Canada’s regulatory frameworks.

Export Controls, the Controlled Goods Program and Sanctions are legal mechanisms designed to protect national security, support international obligations and prevent the unauthorized transfer or misuse of sensitive knowledge, goods and technologies.

Whether collaborating internationally, shipping equipment, sharing technical data or working with restricted materials, researchers play a key role in ensuring compliance.

This page introduces these requirements and outlines how they apply to academic research activities, helping you navigate your obligations while enabling innovation and collaboration. For further information, please contact research.security@uoguelph.ca.

What are Export Controls?

Export controls regulate the transfer of certain goods, technologies and technical data across borders, as well as the sharing of controlled information with foreign entities or individuals. In Canada, export controls are primarily governed by the Export and Import Permits Act and administered by Global Affairs Canada. Failure to adhere to these laws can result in prosecution by the Government of Canada, with possible fines and/or imprisonment. 

Export controlled items are listed on the Export Control List (ECL) and may include dual-use technologies, advanced research equipment, cryptographic items and sensitive scientific data that could have military, security or strategic applications.

Considerations for Universities

Export controls apply to a wide range of university activities, not just physical shipments. Researchers must consider compliance when:

  • Shipping equipment or materials internationally
  • Sharing technical data, research results or software with collaborators abroad
  • Participating in international research collaborations or contracts
  • Traveling with research equipment, laptops or sensitive data

Foreign Export Controls

Most countries will have export control laws specific to their national interests. While we work in Canada, we must be mindful of other countries’ export control laws when employing or partnering with their citizens or contracting with companies or other entities within their boundaries. With increasing frequency, foreign partners request that the University adhere to another country’s export control laws. 

Assessing for Export Controls

To determine whether export controls apply, researchers and administrators should assess:

  • Whether the item, software or data appears on Canada’s Export Control List (ECL)
  • The destination country and whether additional restrictions or permits apply
  • The end use and end user, including potential military or prohibited applications
  • Any contractual or funding conditions related to export controls

In many cases, an export permit may be required before transferring export-controlled items or information outside Canada.

Exporting goods on the Export Control List

If an item appears on Canada’s Export Control List, it does not automatically mean it cannot be exported. Instead, it usually means that an export permit is required.

A Canadian broker, working on behalf of the foreign collaborator/partner, may apply to the Government of Canada for an export permit.

Exporting research outputs on the Export Control List

Export controls can also apply to research results and intellectual property (IP), not just physical items.

Issues can arise when a university:

  • Shares, licenses or assigns rights to research results with a foreign partner
  • Transfers technology that is listed on the Export Control List

If this happens without proper authorization, it could violate export control laws.

To manage this risk, universities may take one of three approaches:

  1. Require the partner to obtain an export permit before receiving the technology
  2. Obtain an export permit directly before transferring the technology
  3. Make the research publicly available (e.g., through publication), so it is no longer considered a controlled transfer

Publishing research openly ensures the information is accessible to everyone, which can remove certain export control restrictions, however research security must still be considered.

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What are Controlled Goods?

Controlled goods are sensitive items regulated under Canada’s Defence Production Act. They generally include military and defense-related goods, as well as certain dual-use technologies that may have both civilian and military applications. Individuals and organizations need to register in the Controlled Goods Program (CGP) to examine, possess or transfer controlled goods in Canada.

This can encompass physical items (e.g., components, equipment), as well as technical data, software and blueprints related to those goods. The CGP, administered by Public Services and Procurement Canada, is designed to ensure that these items are handled securely and accessed only by those authorized to protect Canada’s national security.

Considerations for Universities

Universities may encounter controlled goods in areas such as engineering, aerospace, physics, advanced manufacturing and applied sciences. When controlled goods are involved, institutions must ensure that:

  • The university is appropriately registered under the CGP (if required)
  • Individuals with access are security assessed and authorized
  • Access to labs, equipment and data is restricted to approved personnel
  • Policies and procedures are in place for secure storage, handling and transfer of controlled goods

Failure to comply can lead to legal penalties and may impact research funding and partnerships.

Assessing for Controlled Goods

Researchers and administrators should assess whether their work involves controlled goods by considering:

  • The nature of the materials, equipment or technology used in the research
  • Whether items or technical data appear on Canada’s Controlled Goods List
  • The intended and potential applications of the research (including defense-related uses)
  • Requirements outlined in contracts, funding agreements or partner terms

Early identification is critical to ensure that appropriate controls and approvals are in place before research begins.

If a researcher wishes to work with a Controlled Good, please contact research.security@uoguelph.ca. Applications will require a description of the controlled good, a list of all individuals who will have access to the controlled good and a security plan. 

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What are Sanctions?

Sanctions are legal measures the government uses to put pressure on foreign countries, governments, organizations or individuals that are involved in activities Canada considers harmful—such as human rights abuses, threats to international peace, terrorism or serious corruption.

Sanctions can include asset freezes, travel bans, trade restrictions and financial prohibitions.

When sanctions are implemented in Canada, Canadians abroad and those in Canada, can face limitations in dealing or collaborating with sanctioned countries, or listed individuals and entities. 

Considerations for Universities

Universities must be aware of how Canadian sanctions may affect their activities and international relationships. While sanctions do not automatically prohibit employing, educating or training individuals from sanctioned countries, enrolling students or hiring or hosting academic staff in these circumstances requires consideration, particularly where activities involve listed goods, sanctioned services or sectors, or links to listed individuals or entities.

Institutions should remain alert to attempts to circumvent sanctions through international academic collaboration, as foreign students, visiting scholars or workers with access to institutional networks, research and infrastructure may pose risks related to information collection, data theft or inappropriate knowledge transfer, especially where research has potential military or surveillance applications.

Assessing for Sanctions

Due diligence can help assess whether an activity may trigger sanctions. Screen any proposed engagement to determine if the individual or entity you propose to engage with is directly subject to Canadian sanctions using:

This includes, for example, hiring faculty, hosting visiting scholars, admitting international students or those involved in research collaborations. It is generally prohibited to deal directly with listed individuals and entities – even indirectly, such as through a third party – including if that third party is not Canadian and/or is located outside of Canada.

Questions to consider:

  • Am I dealing with a person that deals with a listed individual or entity?
    • Does the prospective student, researcher or research collaboration have any connection, even indirectly, with a listed individual or entity?
  • Does the activity involve, or benefit, any listed individuals or entities either directly or indirectly?
  • Am I inviting a person from a sanctioned country to Canada (or to a third location)?
    • Consider indirect dealings with listed persons or entities.
  • Am I making or receiving a payment to or from a person or entity (either directly or indirectly), or through a bank, in a sanctioned country?
    • Is the person invited to Canada doing so?
  • Am I in any way facilitating a sanctions contravention?

If you need assistance in assessing for sanctions, please contact research.security@uoguelph.ca.

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