Re: Inquire about ECCN for Debian GNU/Linux and how to deal with revised EAR
Dear Paul and Osamu,
Thank you for the informations.
> If you reach a conclusion, please let us know the results.
The results are as follows.
>> [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?
Although it may not be necessary,
I sent a notification to BIS after self classification on our items.
>> [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 ?
It is explained in Note 1 on this page.
https://www.bis.doc.gov/index.php/policy-guidance/encryption/1-encryption-items-not-subject-to-the-ear
Sincerely,
Yuichi Ikeda
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