Disposing of controlled goods: the records to keep

What the Controlled Goods Regulations expect you to record when controlled goods are destroyed, and what to ask a destruction company for.
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Guide for Designated Officials. 4 minute read.

When controlled goods reach the end of their life, the disposal is part of your compliance record. This guide covers what you have to be able to show, and what to ask of whoever destroys them.

Who may take them

In Canada, a person may only examine, possess or transfer controlled goods if they are registered with the Controlled Goods Program or exempt from registration. That applies to a recycler or a destruction company the same way it applies to you.

So the first question for any disposal is simple: is the company that will hold your controlled goods registered? Ask for a copy of its registration certificate, and note the date it is valid to.

What your records must show

Section 10 of the Controlled Goods Regulations (SOR/2001-32) sets out the conditions of registration. Among them, a registered person must keep records of the controlled goods it receives, the controlled goods it transfers, and the controlled goods it disposes of.

For a disposal, the record has to include a description of the manner and the date of disposition. For a transfer, it has to include the date and the identity and address of the person the goods went to. These records are kept for the period of registration and for 5 years after it ends.

What to ask your destruction company for
A copy of its Controlled Goods Program registration certificate, with the valid-to date
A receipt or receiving report when the goods change hands, with the date
A certificate of destruction that states the method and the date of destruction
The place where the destruction was done
Your own part numbers or serial numbers on the certificate, when your procedure needs them
A lot or reference number that ties the pickup, the receipt and the certificate together

Where it is destroyed matters

Destruction inside Canada, by a registered company, keeps the disposal inside the program you already work under. Sending controlled goods out of the country is an export, and that is a different set of rules and permits.

If something goes wrong

The regulations also require a registered person to report an actual or potential security breach involving controlled goods to the program within 3 days. If a shipment for destruction goes missing or arrives short, your Designated Official needs to know the same day.

How EDI fits

EDI is registered with Canada's Controlled Goods Program, valid to 2029-05-29, and destroys controlled goods at its own facility in Orillia, Ontario. See controlled goods destruction or look at a sample certificate.

Based on the Controlled Goods Regulations, SOR/2001-32, section 10, and the Controlled Goods Program's published guidance.

General information, not legal advice. Check the current text of the rules, or ask your own advisor, before you rely on it.

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