New BIS rules for encryption export

Hi all,

I am in the process of preparing my app for internal testing via TestFlight, and am at the stage of setting up setting up export compliance documentation.

I registered on the BIS Snap-R site in order to file for an Encryption Registration Number. However I found that that option is no longer available, and I can no longer request an ERN online.

After doing some quick Googling I found changes in the law mean that ERNs may no longer be required as of the 20th of September 2016.

However, iTunes Connect still requires me to either enter an ERN, or state that I have an exemption.

My app is a Cordova app that connects to the YQL API over HTTPS, a WordPress REST API over HTTP (for now), and grabs thumbnails from YouTube over HTTPS.

Should I mark that my app is exempt from the US export rules? Or is will there be new guidance on the support docs soon?

Cheers, Joe

P.S. Sorry if this has been answered, couldn’t find any relevant discussion with regards to ERN / Export Compliance after September 20th.


yes, state that you are exempt.


I am also in similar situation as @jpweg93. Am unable to register in ERN as terms and condiitons are changed in it.

My App uses HTTPS and SqlCipher for encrypting database. Should I also mark my app exempt from the US export rules?

Thanks in advance.

Do you get what you want. I'm in the same canal now. Do I need to opt for export compliance, some of the posts says that it has been removed since 20th September 2016. Help me out please.

Ok, so I don't need to file "Encryption Registration", but according to: I still needd to send annual reports to and with subject “Self-classification report for ERN R######”. So question is, how to obtain ERN number where I can't request for it?

Thanks in advance for any help

Read the link you referenced....

"When an encryption registration is submitted via SNAP-R, SNAP-R will issue an Encryption Registration Number (ERN), which will start with an “R” and will be followed by 6 digits, e.g., R123456. This registration number is confirmation that BIS has received your encryption registration."

Unless you are really using encryption for something serious (i.e. beyond https, decoding receipts, assuring compliance with purchases, and username/password stuff), I think you can ignore all of this. If I am wrong, I will see you in ****. (edit - the word that is starred out by Apple automated editing is the four letter word for prison starting with "J"!)