From the
2007 Export Controls List PDF - which is also used to define the list of controlled goods as per DPA and CGP (see
this document - specifically,
"For the purpose of the Controlled Goods Program (CGP), anyone dealing with the following controlled goods in Canada identified in the ECL is required to register with the CGP..."):
2-13.
Armoured or protective equipment and constructions and
components, as follows:
c. Helmets manufactured according to military standards or
specifications, or comparable national standards, and specially
designed components therefor, i.e., helmet shell, liner and
comfort pads;
d. Body armour and protective garments manufactured according
to military standards or specifications, or equivalent, and
specially designed components therefor.
As with most legislation/regulation/etc. there are footnotes and one must
always read the footnotes!!!
Note 3:
2-13.c. and 2-13.d. do not control helmets, body armour or protective garments when
accompanying their user for the user’s own personal protection.
Based upon this, I have doubts that there is a "blanket ban" under the CGP for all types of body armor, and though I am by no means an expert here and will stand corrected if proven wrong, I would go so far as to suggest that even military style (or surplus) SAPI plates wouldn't be an issue given the wording of "Note 3".
Obviously, a further inquiry with PWGSC and DFAIT making reference to both s. 2-13 and the footnotes seeking greater clarification as it pertains to civilian ownership/use of personal body armor (range safety, etc.) should be the next step here. Even seasoned government bureaucrats can get it wrong from time to time, more especially so if the legislation & regulations are complex as in this case. If it were me, I'd seek a second opinion...
'Fly