Inquire about ECCN for Debian GNU/Linux and how to deal with revised EAR
Dear Sir/Madam,
I like excellent package system of Debian operating system.
I have been using for a long time. Thank you.
I'm sorry I made a duplicate question.
I know that it is not a good manners, however,
we have to found clear description about ECCN for a product,
or have to make an inquiry to maker as a procedure.
I think that past similar questions may be from the same reason.
I have been checked almost all related e-mails and websites.
In addition, I found that paragraph Part 740.13(e) of the EAR
has been revised to "[Reserved]".
According to the legal issues website (https://www.debian.org/legal/),
the past notifications had sent based on paragraph
Part 740.13(e)(1) of the past EAR.
Therefore, please let me ask questions about the following.
[1] Is the Debian operating system classified under ECCN 5D002 ?
On the USExportControl website (https://wiki.debian.org/USExportControl),
it has been described "may be" covered under ECCN 5D002.
This cannot treat as our confirmation,
so I had to ask a duplicate question as a procedure.
Is it still "may be"? Are there more clearly description?
[2] Can the Debian operating system be treated as out of EAR subject
under the current EAR ?
I think that paragraph Part 742.15(b) of the current EAR
is similar to paragraph Part 740.13(e) of the past EAR.
But there are some differences.
Are there no need to notify BIS again ?
Notes
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BIS - Bureau of Industry and Security
EAR - The U.S. Export Administration Regulations
ECCN - Export Control Classification Number
Sincerely,
Yuichi Ikeda
at Mitsubishi Electric Corporation
Manufacturing Engineering Center
Integrated Production Engineering Dept.
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