June 25 changes to BIS 742.15 How does it impact SSL iPhone App export compliance

Posted by Rob on Programmers See other posts from Programmers or by Rob
Published on 2010-06-30T17:01:09Z Indexed on 2011/02/01 15:33 UTC
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This question isn't strictly development-related but I hope it's still acceptable :)

On June 25, 2010 the BIS updated 742.15 and of interest to me is the new 742.14(b)(4) "Exclusions from mass market classification request, encryption registration and self-classification reporting requirements" and 742.15(b)(4)(ii) which states…

(ii) Foreign products developed with or incorporating U.S.-origin encryption source code, components, or toolkits. Foreign products developed with or incorporating U.S. origin encryption source code, components or toolkits that are subject to the EAR, provided that the U.S. origin encryption items have previously been classified or registered and authorized by BIS and the cryptographic functionality has not been changed. Such products include foreign developed products that are designed to operate with U.S. products through a cryptographic interface.

I take this to mean that my Canadian produced product that uses https is now excluded from requiring a CCATTS.

What does everyone else think?

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