In this contribution, we use a governance lens to assess the possibilities for political participation of non-governmental organizations (NGOs) in the European Common Foreign and Security Policy (CFSP). We illustrate their engagement in the case of the European Code of Conduct/Common Position on Arms Export. We show that, while processes related to the emergence of the Code fit the description of intergovernmental approaches, developments since then, however, more closely resemble governance. With the growing institutionalization of the CFSP in general, and that related to the Code in particular, access points for NGOs became increasingly available. Through information and symbolic politics as well as rhetorical entrapment, civil society organizations contributed not only to the tightening and widening of the Code's provisions, but also to the increasing willingness of governments to provide information to each other as well as their own publics about arms exports.