关于iOS应用提交Annual Self-Classification Report的ECCN编码确认问询
Hey there! Let’s work through this ECCN classification puzzle for your iOS app that only makes HTTPS requests (no other network behavior). Here’s a breakdown of the codes you’re considering, and which one fits your use case:
Key Context First
ECCN codes for software focus on whether your app includes or uses controlled encryption capabilities. Since your app relies solely on standard HTTPS (which uses TLS/SSL), we can narrow this down based on how your app implements that encryption.
Breakdown of the Codes You’re Evaluating
5D002: This applies to software that contains or uses encryption functions not covered by exceptions in the Export Administration Regulations (EAR). However, if your app uses iOS’s native HTTPS APIs (like
URLSession,WKWebView, or third-party libraries built on these system APIs), you’re likely covered by the Category 5 Part 2 Note 4 exception—meaning 5D002 doesn’t apply here. This exception covers software that uses standard, widely available encryption protocols (HTTPS/TLS) without custom encryption logic.5D992: This is a catch-all for encryption software not covered by 5D002. Within this, 5D992.c is specifically for software that:
Only uses standard encryption algorithms (e.g., HTTPS, TLS, SSL, SSH) and does not contain or use any other controlled encryption features.
This is exactly your scenario! If your app only sends/receives HTTPS requests using iOS’s native encryption stack, no custom encryption, no peer-to-peer networking, no encryption key management beyond what the system handles automatically—5D992.c is the correct ECCN code.
Quick Validation Checks
To be 100% sure, confirm these points about your app:
- You’re not implementing any custom encryption logic (e.g., rolling your own TLS, encrypting data locally with non-standard algorithms).
- All network traffic is strictly HTTPS using system-provided APIs.
- Your app doesn’t handle sensitive encryption operations like key generation/storage outside of what iOS manages for HTTPS.
If all these are true, 5D992.c is the right pick for your Annual Self-Classification Report.
内容的提问来源于stack exchange，提问作者user8527410
