Export Controls on Goods and Technology to Russia

Summary#

These are final changes to the Special Economic Measures (Russia) Regulations that bar many exports of goods and technologies to Russia. The rules rely on a publicly available Restricted Goods and Technologies List prepared by Global Affairs Canada and came into force on March 24, 2022 (published in the Canada Gazette on April 13, 2022).

What it does#

• Prohibits any person in Canada and any Canadian outside Canada from exporting, selling, supplying or shipping any good to Russia or to a person in Russia if that good appears on the Restricted Goods and Technologies List.
• Prohibits providing any technology (including technical data, training, consulting or know‑how) to Russia if it is on that list.
• Creates several specific exemptions. Examples include:
  • goods temporarily exported for media representatives from Canada or from a partner country listed in Schedule 6;
  • goods used for international nuclear safeguards, chemical weapons inspections, or International Space Station activities;
  • certain software updates for civilian end users owned or controlled by Canadians or nationals of partner countries;
  • civil aircraft and routine supplies or spare parts on board aircraft or ships, in some limited situations;
  • consumer communication devices that are widely available to the public; and
  • personal effects for travellers.
• Replaces a provision to make it unlawful to knowingly do anything that causes, facilitates or assists in activities already prohibited by the regulations.
• Identifies a list of partner countries (e.g., the United States, United Kingdom, France, Germany, Japan, Australia, and many EU members) used for some exemptions. The full list is published in Schedule 6.
• The list of restricted items is not printed in the regulation text. It is published and updated on the Global Affairs Canada website.

Who's affected#

• Canadian exporters and businesses that sell goods, components or technology that could be shipped to Russia. Small and medium businesses that previously exported to Russia may be especially affected.
• Any Canadian located outside Canada who tries to export or supply controlled goods or technology to Russia.
• Airlines, shipping companies and crews in limited ways (for example, rules about spare parts and supplies on board).
• Media representatives travelling temporarily to Russia (there is a specific exemption but it is limited).
• Enforcement and compliance bodies: Royal Canadian Mounted Police and Canada Border Services Agency are named as the main enforcers of the sanctions regime.
• It is unclear from the regulation text exactly how many Canadian firms or which specific goods will be affected — businesses must check the online Restricted Goods and Technologies List to know for sure.

Why it matters#

• These changes tighten Canada’s export controls to deny Russia access to goods and technologies that could support its military or defence-related industries. That is the stated policy goal.
• The measures align Canada with major allies (such as the United States and the European Union) so Canadian exporters are less likely to face extra‑territorial U.S. export controls if Canada enforces similar restrictions.
• Businesses that export to Russia may lose customers and will face new compliance checks. They may need to change supply chains or seek export permits where allowed.
• Breaking the rules can carry criminal penalties. Under the applicable statute, a person who knowingly contravenes the sanctions faces fines up to $25,000 (summary conviction) and possible imprisonment (up to one year summary, or up to five years on indictment).