Brazil and Montenegro Added to AFCCL

Summary#

The Order Amending the Automatic Firearms Country Control List: SOR/2025-41 adds Brazil and Montenegro to Canada’s list of countries that may be considered destinations for certain controlled military firearms and related items. The order was registered and came into force on February 26, 2025.

What it does#

• Adds Brazil and Montenegro to the Automatic Firearms Country Control List (AFCCL).
• Means the government can now consider export permit applications for items that are otherwise prohibited under the Export and Import Permits Act to those two countries.
• Keeps existing safeguards: inclusion on the AFCCL does not guarantee approval. All exports still need a permit from Global Affairs Canada and are examined case by case against human-rights, security, and diversion risks.
• Processing time guidance: complete low-risk applications are generally reviewed within 10 business days; cases needing broader consultation generally within 40 business days.

Who's affected#

• Canadian defence and security manufacturers and exporters who make or trade controlled firearms, weapons, or parts.
• Global Affairs Canada, which will assess and issue any new permits.
• Enforcement agencies: Canada Border Services Agency and the Royal Canadian Mounted Police will continue to enforce export rules.
• Foreign government buyers, including defence or police forces in Brazil and Montenegro, who could now be eligible to receive certain Canadian exports if permits are approved.
• The public: import/export rules and human-rights checks remain in place. The Order is not expected to affect Indigenous treaties or First Nations-led exporters, according to the government’s initial assessment.

Why it matters#

• It opens the possibility for a small number of new defence export opportunities to Brazil and Montenegro, which the government says could support bilateral defence cooperation and trade.
• It does not remove export controls. Each shipment still requires a permit and can be denied if it poses a substantial risk to human rights, security, or could be diverted. The decision rules include criteria from the Arms Trade Treaty (ATT).
• The government estimates roughly 20 additional permit applications over the next 10 years, with an annualized administrative cost of about $55 (2012 dollars). In 2023, Canada issued 0 permits for Montenegro and 17 permits for Brazil for military goods and technology out of 2,846 total military export permits.