When subcontractors must register in the Controlled Goods Program

Learn when subcontractors must register in the program and explore different scenarios to help you decide whether registration is required.

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Subcontractor registration requirements

A subcontractor must register in the Controlled Goods Program if they intend to examine, possess or transfer controlled goods.

Examples of subcontractors that are not required to examine, possess or transfer controlled goods include:

Scenarios

Explore 3 different scenarios to determine whether registration in the Controlled Goods Program is required.

Scenario A

Your aerospace company intends to hire a subcontractor to provide janitorial services. Your company has controlled goods on site and is registered in the Controlled Goods Program.

Question

Since the work will be conducted within the vicinity of controlled goods at your site, must the subcontractor register in the program?

Answer

The subcontractor providing janitorial services is not required to register since they do not intend to examine, possess or transfer controlled goods.
However, your aerospace company is responsible for safeguarding the controlled goods on site and ensuring that unauthorized individuals are not allowed to examine, possess or transfer them. In addition you must:

Scenario B

Your aerospace company intends to hire a subcontractor to manufacture the landing gear for military fighter jets. Neither the blueprints you intend to provide, nor the landing gear itself, are deemed to be a controlled good and there will be no contact with controlled goods.

Question

Since the subcontractor is manufacturing a component of a controlled good, must they register in the program?

Answer

The subcontractor is not required to register since they do not intend to examine, possess or transfer controlled goods.

Scenario C

Your aerospace company intends to hire a subcontractor to install landing gear on military fighter jets.

Question

Since your company is registered in the Controlled Goods Program and the work will be entirely conducted on your company site, must the subcontractor also register in the program?

Answer

The subcontractor must register since they intend to examine military fighter jets when installing their landing gear; this is regardless of where the examination will take place.

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