Re: Inquire of ECCN/LE of Debian 6.05
Dear Steve Langasek,
Thank you.
> If you are intending to export products from the US that include the Debian
> OS, then it would appear you would need to confirm this yourselves, yes.
> Since you appear to be based in Japan, I don't understand why you would need
> an ECCN certification from the BIS. Does Japan not have its own process for
> ECCN determinations under the Wassenaar Arrangement?
Japan has its own process for export control under theWassenaar Arrangement.
However, US regulations require the we (even though located outside US) need to confirm the ECCN under US regulations in the case of that we export US origin product (technical information) from our country (outside US) to other country.
This is the reason we request the ECCN information to you.
I understand the correct status. Thank you for you information.
Kind regards,
Rieko Nagao
*******************************************
Rieko Nagao
Gyoseishoshi Lawyer
NAGAO Legal Affairs Office
4-9-13-505 Yushima, Bunkyo-ku,
Tokyo 113-0034, Japan
Mobile: +81-90-5777-4775
E-mail: nagao-legal@bd5.so-net.ne.jp
URL: http://www.nagao-law.com
*******************************************
On 2013/06/11, at 14:40, Steve Langasek <vorlon@debian.org> wrote:
> On Tue, Jun 11, 2013 at 01:50:19PM +0900, Rieko Nagao wrote:
>> Dear Paul Wise,
>
>> Thank you.
>
>> Does this mean you (Debian) doesn't have the ECCN certified by BIS?
>
> Correct, Debian has not requested an ECCN certification from the BIS.
> Debian does export its software under the TSU exception as described in CFR
> 740.13(e), including the provisions for notification to the BIS of
> publication URLs until recently (when the BIS informed Debian they had
> sufficient information and asked us to stop proactively notifying of new
> software versions).
>
>> Do we need to confirm the specification of your product by ourselves?
>
> If you are intending to export products from the US that include the Debian
> OS, then it would appear you would need to confirm this yourselves, yes.
> Since you appear to be based in Japan, I don't understand why you would need
> an ECCN certification from the BIS. Does Japan not have its own process for
> ECCN determinations under the Wassenaar Arrangement?
>
> --
> Steve Langasek Give me a lever long enough and a Free OS
> Debian Developer to set it on, and I can move the world.
> Ubuntu Developer http://www.debian.org/
> slangasek@ubuntu.com vorlon@debian.org
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