Canada: SEMA Russia Regulations amendment (SOR/2022-067) — Restricted Goods and Technologies List export ban

Mechanism

SOR/2022-067 was registered and came into force 24 March 2022 as an amendment to the Special Economic Measures (Russia) Regulations (SOR/2014-58), Canada's principal Russia-sanctions instrument. It introduced the "Restricted Goods and Technologies List" — maintained and published by Global Affairs Canada outside the regulation text itself — and made it prohibited for any person in Canada and any Canadian outside Canada to export, sell, supply or ship any listed good, or to provide any listed technology, to Russia or to any person in Russia. The regulatory impact statement describes the list as covering items with "potential military and civilian applications" spanning electronics, computers, telecommunications, sensors and lasers, navigation and avionics, marine, aerospace and transportation. "Technology" is defined broadly to include technical data and technical assistance, not only physical goods.

Severity basis

The regulatory impact statement discloses that Canadian merchandise exports to Russia totalled just over CAD 632 million in 2020 (the latest data available at filing), carried by approximately 840 Canadian exporting companies, mostly SMEs — the scale of bilateral trade this instrument reaches into, even though the statement does not break out a value specific to the restricted-goods subset alone. Severity 4 reflects the list's breadth (an entire new dual-use/civilian-military goods-and-technology category, not a single product line) layered onto that trade-value context, rather than a scoped tariff/quota/coverage figure — hence mixed rather than quant.

Downstream implications

• Establishes the list mechanism later amended (e.g. SOR/2022-102's Schedule 6/7 additions)

to add further Russia export-ban categories — any company trading dual-use electronics, aerospace, marine or navigation equipment with Russia is in scope by construction.

• Because the list itself lives outside the regulation (Global Affairs Canada's published

list, not the gazette text), its contents can be expanded administratively without a new SOR — downstream monitoring needs the list page, not just future amendments.

Open questions

• Whether Global Affairs Canada's Restricted Goods and Technologies List has since been

revised to add or drop categories beyond what the original March 2022 notice described.