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As economic sanctions, supply-chain disruptions, and changing trade relationships become increasingly complex, it has become imperative for Canadian companies to develop a knowledge of export controls as an important part of managing business risk.

This is extremely imperative for those businesses involved in international trade, technology, defence, manufacturing, agriculture, and other regulated industries.

Canada regulates the export of certain goods and technologies through the Export and Import Permits Act (EIPA) and the Export Control List (ECL), which can include military and strategic goods, dual-use technologies, nuclear-related materials, and certain agricultural and other products.

During the last year as the Federal government responds to national-security, technological and economic-security risks, the need to understand not only what they export but also where it goes and who uses it, became even more important to businesses.

In 2025, one of the major changes occurred as Canada expanded controls on advanced technologies when new controls were introduced for areas including semiconductor manufacturing, quantum computing, temperature-coating technologies, and advanced metal additive manufacturing, such as sophisticated 3D-printing equipment.

These controls mean that companies exporting certain high-tech products or technology may now need permits where they previously did not.

Another big development came into play when Bill C-15, which received Royal Assent in March 2026, amended the EIPA to give the government authority to control exports or imports when necessary to protect Canada’s economic security. 

Another change is the continuing evolution of Canada’s ECL through international agreements. 

These developments increase compliance costs and risks for businesses since companies may need stronger product-classification procedures, screening of customers and end users, record-keeping, employee training and monitoring of regulatory changes. 

The Chamber asked former Cambridge MP Bryan May, now a Senior Strategic Advisor with Bondy & Associates, a Cambridge-based boutique government-relations and strategic advisory firm, about issues surrounding export controls: 

Q.  How will changes to Canadian export control regulations affect the ability of businesses to sell internationally?

BM.  Honestly, the trend is toward more friction, not less. Global Affairs Canada put out an updated Guide to Canada's Export Control List that came into force on May 1, which folds in commitments Canada has made through multilateral regimes up through January. That part's fairly routine. Some new items got added, like certain lasers, helium turbo expanders, and specific chemicals, while a handful of other controls got removed. The bigger deal is that Canada is also pushing its own controls further than the multilateral baseline. 

There's a proposal out for consultation that would add new controls on semiconductor and advanced manufacturing technology, and if it goes through, exporting those items anywhere outside the U.S. would need an individual permit, with no blanket general permits available. So if you're in that space, you're looking at permit by permit, destination by destination approval rather than the streamlined process you might be used to. There's more coming too. I’ve read that trade lawyers expect Canada to eventually get authority to control goods it considers critical to its own supply chains once a pending amendment to the Export and Import Permits Act goes through.

Q.  What impact will foreign export control changes have on Canadian companies in global supply chains?

BM. This is where U.S. policy honestly matters more day to day than anything Canada is doing itself. The U.S. rolled out a new tiered approach to Section 232 tariffs on steel, aluminum, and copper products in April, and separately, a June executive order is ramping up customs scrutiny. U.S. Customs wants more ownership and business affiliation info from importers, bond requirements are going up, and Canadian companies don't get a pass just because of CUSMA.

On top of that, CUSMA itself is going through the formal review that started on July 1, so there's real uncertainty about whether the terms governing cross-border trade could shift. If you're plugged into a U.S. or allied supply chain, you can get caught up in all this even when nothing you're doing directly triggers a Canadian control. A customer's compliance problem or a foreign supplier's re-export restriction can still stall your shipment.

Q. How can businesses stay compliant with emerging tech like AI and cybersecurity products?

BM. This is probably the trickiest area right now because Canada doesn't have a dedicated AI law yet. The old AI and Data Act died in early 2025, though a replacement bill is expected sometime this year.  So, for now AI related exposure runs through the general export control list and this idea of a "deemed export”.  If you give a foreign national access to controlled technical data, even though a cloud platform or a screen share, that can count as an export. Global Affairs Canada put out specific guidance on how export permitting applies to controlled technology stored or moved through the cloud, worth reading closely if your product involves models, source code, or technical data that could brush up against controlled categories. 

The practical advice I’m hearing from trade lawyers is consistent; update your compliance procedures to cover intangible transfers, lock down access to controlled tech with role-based permissions and encryption, keep logs of who's touching shared drives and cloud storage, and train your engineering and business development people, because an informal conversation or a demo can trigger obligations without anyone realizing it.

Q. What are the legal, financial, and reputational risks of non-compliance, and how do you mitigate them?

BM.  I’m not a lawyer so take the following with a grain of salt, and I’d recommend any of the companies involved consult a lawyer who’s a trade specialist. It's a real risk, not just theoretical. Violating sanctions is a criminal offence, enforced jointly by CBSA and the RCMP, and enforcement has quietly been ramping up. CBSA's counter proliferation unit has been doing exporter risk analyses and trade verifications throughout 2025, and just looking at Russia related shipments alone, CBSA has reviewed over 1,500 shipments since the invasion, handed out 14 fines, and flagged several for seizure. 

There's also a co-ordination angle that's easy to miss. If your company gets flagged for enforcement in another G7 country, Canada is increasingly likely to also come knocking, because the G7 countries are sharing information more actively, and Canadian authorities are specifically watching for sanctions evasion through shell companies and roundabout trade routes. On the mitigation side, it's not glamorous but it works.  Know your classification, screen your counterparties on an ongoing basis rather than just once, restrict who internally can access controlled data, and if you find a problem, talk to trade counsel about self-disclosure sooner rather than later. It tends to go a lot better than getting caught cold. 

Q.  How should businesses prepare for future export control developments?

BM.  A few things worth keeping an eye on: that EIPA amendment that could bring in critical supply chain controls, the sanctions and anti-money-laundering rules tightening up, partly driven by an FATF evaluation of Canada back in June, and the fact that Global Affairs Canada merged its Trade Controls Bureau and Sanctions Bureau, which suggests these two areas will move together more than they have in the past. If I were advising a business right now, I'd say don't treat your export compliance review as an annual thing anymore. Given how fast this is all shifting, quarterly check-ins on the Canada Gazette and Global Affairs bulletins are probably more realistic.  Also, having a senior leader on your team accountable for staying on top of these potential changes would be wise.