Export Compliance - Do I need ERN ?

Question regarding the need for an ERN when submitting an update to the app.

- app stores basic information locally as of now

- Utilize AES-128/256 encryption to encrypt locally stored customer info - Proposed change

- https for data transmission to services (Data not encrypted while sending to services, as https automatically secures/encrypts)


Do I need to say - YES (for encryption changes from Last build) when I will update my app.


If yes, is my app under exemption category? Do I need an ERN number to submit the app.

Are you under USA Export controls concerning encryption? Are you in the USA?


I don't think you qualify, in any case.

I am in USA. App is to be distributed in US and Canada App store.


I request you to help me unserstand below details, As I am unaware of these facts:

Are you under USA Export controls concerning encryption? - Please help me, how do I know if I am under USA Export control or not


App encrypts data (it is customer's information - say Name, Email, phone and some other etc.) to store locally just to prevent any unauthorized access (theft etc). No enrypted data sent via services, since https is secured itself.

>I am in USA. App is to be distributed in US and Canada App store.


Google has this to say about that:


Although AES is free for any use public or private, commercial or non-commercial programs that provide encryption capabilities are subject to U.S. export controls and sanctions administered by the Bureau of Industry and Security (BIS) under the Export Administration Regulations (EAR) and the Commerce Control List (CCL). Most commercial encryption products have a license exception assigned to them by the BIS. The exception allows them to be exported to specified destinations without having to obtain a separate license each time from the Commerce Department. None of these license exceptions, however, allow encryption products to be exported to the following embargoed countries: Cuba, Iran, Iraq, Libya, North Korea, Sudan and Syria.

Thanks for your reply.


So as per your recommendation, I donot need ERN Number.

Also, I have to say - No changes made in Encryption feature since last build was submitted?



Am I correct?

Accepted Answer

I'd add a short change list/summary of all changes to the review notes for the latest build.

Export Compliance - Do I need ERN ?
 
 
Q