Encryption Controls

Questions and answers about Encryption Controls


    Question: Encryption rookie question:  The actual ECCN for an item does not change – I get that – so let’s say it’s 5A002.a.1.   My question is about the other element (whatever it’s called) where it is either a1, a2, b1, b2, b3, b4 under EAR 740.17.  It that also “permanent” once assigned, or can […]


    Question: Hoping for guidance from the membership.  Here is the basic scenario: A “family” of “restricted” encryption items /740.17(b)(2) products is authorized on the Encryption Licensing Arrangement – various models in the family The 400 model, is exported under the Encryption Licensing Arrangement The product fails and customer wants a replacement. Two scenarios: o   The […]


    Question: I would appreciate feedback from the membership about how do you conduct your classification analysis for products that contain encryption.  how do you communicate with your Engineering team, Program Management, etc the encryption regulations so that they help you conduct the proper classification evaluation.   I’m currently using a home-made “Encryption Review Questionnaire” a  question/answer […]


    Question: Our I.T. team is contemplating adding encryption to all laptops andI’m concerned for those who travel frequently outside the U.S. Would any members have a listing of countries where traveling with a laptop protected by encryption (encrypting sensitive business data and programs such as e-mail) is restricted or not allowed ?  Thanks.

  • Semi-annual encryption report

    Question: A question related to the semi-annual encryption report as described inEAR 740.17(e). This section states “Semi-annual reporting is requiredfor exports to all destinations other than Canada, and for reexports fromCanada…” We have an encryption software product (5D002 but approved to uselicense exception ENC) that needs to be included on the report. In a fewinstances, […]

  • China import reg for encryption items

    Question: Has anyone had any experience with or have knowledge about the new Chinaimport reg. for encryption items?  I read about it in Baker McKenzieJan. 2010 newsletter and could find very little else about it.  It lists 9categories of items, but also says if you have knowledge that there isencryption in your product you need […]

  • Encryption Controls Q&A 1

    S.KOREAN ENCRYPTION EXPORT CONTROLS: Does anyone know if there are export controls on encryption in South Korea (e.g. requiring an export license to ship from South Korea)? If yes, do you have any idea where there may be an English version of the export regulations?

  • Encryption Controls Q&A 3

    Should we apply for BIS review for a software that we purchased when the vendor of the software already provided a copy of the CCATS to us? We purchased an encryted software classified as 5D002. We might have to share it with our US subsidiaries. The vendor already sent it for review to BIS in […]